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Schwartz, Colin
From: Schwartz, Colin
Sent: Tuesday, November 01, 2016 4:23 PM
Subject: Notice of Issuance of Permit to Construct on the Uintah and Ouray Indian Reservation
This is to notify you that the EPA has issued a final Clean Air Act (CAA) synthetic minor source permit to
construct for the existing Questar Pipeline Company Fidlar Compressor Station pursuant to the Tribal Minor
New Source Review (MNSR) Permit Program at 40 CFR Part 49. The final MNSR permit and administrative
permit record can be accessed in PDF format on our website at: http://www.epa.gov/caa-permitting/caa-permits-
issued-epa-region-8.
In accordance with the regulations at §49.159(a), the permit is effective as of the date of this notice, on
November 1, 2016. Within 30 days after a final permit decision has been issued, any person who filed
comments on the proposed permit or participated in a public hearing may petition the Environmental Appeals
Board (EAB) to review any condition of the permit decision. The 30-day period within which a person may
request review under this section begins when we have fulfilled the notice requirements for the final permit
decision. Motions to reconsider a final order by the EAB must be filed within 10 days after service of the final
order. A petition to the EAB is under Section 307(b) of the CAA, a prerequisite to seeking judicial review of
the final agency action. For purposes of judicial review, final agency action occurs when we issue or deny a
final permit and agency review procedures are exhausted.
Thank you,
Colin C. Schwartz
Environmental Scientist
Air Permits Division
US EPA Region 8- Denver, CO
303-312-6043
1
Schwartz, Colin
From: Schwartz, Colin
Sent: Tuesday, November 01, 2016 4:14 PM
To: '[email protected]'
Cc: Daly, Carl; Smith, Claudia; '[email protected]'; [email protected]; Reynolds,
Cynthia
Subject: Final SMNSR Permit for Fidlar Compressor Station
Attachments: FinalCoverLetter_and_Permit_signed.pdf
Mr. Bassett,
I have attached the final requested permit for the Fidlar Compressor Station issued pursuant to the Tribal Minor
New Source Review (MNSR) Program at 40 CFR Part 49. We will also be posting the final MNSR permit and
response to comments in PDF format on our website at: http://www.epa.gov/caa-permitting/caa-permits-issued-
epa-region-8.
In accordance with the regulations at §49.159(a), because no comments were received on the proposed permit
during the public comment period, the final permit is effective as of the date of this notice, on November 1,
2016. Within 30 days after a final permit decision has been issued, any person who filed comments on the
proposed permit or participated in a public hearing may petition the Environmental Appeals Board (EAB) to
review any condition of the permit decision. The 30-day period within which a person may request review
under this section begins when we have fulfilled the notice requirements for the final permit decision. Motions
to reconsider a final order by the EAB must be filed within 10 days after service of the final order. A petition to
the EAB is under Section 307(b) of the CAA, a prerequisite to seeking judicial review of the final agency
action. For purposes of judicial review, final agency action occurs when we issue or deny a final permit and
agency review procedures are exhausted.
If you have any questions or concerns regarding this final permit action, or would like a paper copy, please
contact me.
Thank you,
Colin C. Schwartz
Environmental Scientist
Air Permits Division
US EPA Region 8- Denver, CO
303-312-6043
1
Schwartz, Colin
From: Schwartz, Colin
Sent: Thursday, September 01, 2016 4:27 PM
Subject: Notice of Public Comment Period – Proposed Synthetic Minor New Source Review
Permit on the Uintah and Ouray Indian Reservation
Attachments: Bulletin Board Notice - QPC Fidlar CS SMNSR.docx
In accordance with the regulations at 40 CFR 49.157 and 49.158, the EPA is hereby providing notification of
the availability for public comment of the proposed Clean Air Act synthetic minor New Source Review permit
for the following existing source located on the Uintah and Ouray Indian Reservation:
Questar Pipeline Company – Fidlar Compressor Station
Electronic copies of the proposed permit, technical support document, application and other supporting permit
information may be viewed online at http://www.epa.gov/caa-permitting/caa-permit-public-comment-
opportunities-region-8.
Paper copies of the proposed permit, technical support document, application, and other supporting permit
information may be reviewed by contacting the Federal and/or Tribal contacts identified on the attached public
notice bulletin.
Comments may be sent by mail to:
US EPA Region 8
Air Program Office
1595 Wynkoop Street, 8P-AR
Denver, CO 80202
Attn: Tribal NSR Coordinator
or
Electronically to [email protected]
In accordance with the regulations at §49.157, the Agency is providing a 30-day period from September 2, 2016
to October 2, 2016, for public comment on this proposed permit. Comments must be received by 5:00 p.m. MT
October 2, 2016, to be considered in the issuance of the final permit. If a public hearing is held regarding this
permit, you will be sent a copy of the public hearing notice at least 30 days in advance of the hearing date.
Colin C. Schwartz
Environmental Scientist
Air Permits Division
US EPA Region 8- Denver, CO
303-312-6043
1
Schwartz, Colin
From: Schwartz, Colin
Sent: Thursday, September 01, 2016 4:27 PM
To: '[email protected]'
Cc: Morales, Monica; Smith, Claudia; '[email protected]'; [email protected];
Reynolds, Cynthia
Subject: Proposed Synthetic Minor NSR Permit for Fidlar Compressor Station
Attachments: Bulletin Board Notice - QPC Fidlar CS SMNSR.docx; QPC Fidlar CS Proposed Permit
SMNSR-UO-000002-2013 001.pdf; Cover Letter with Dates and Stamp.pdf; QPC Fidlar
CS TSD SMNSR-UO-000002-2013 001.pdf
Mr. Bassett,
I have attached the requested proposed permit, the accompanying technical support document, and the public
notice bulletin for the Fidlar Compressor Station. We will also be posting the proposed permit, technical
support document, public notice bulletin, application and other supporting permit information in PDF format on
our website at http://www.epa.gov/caa-permitting/caa-permit-public-comment-opportunities-region-8 by the start of the
public comment period.
In accordance with the regulations at 40 CFR 49.157 and 49.158, we are providing a 30-day period from
September 2, 2016 to October 2, 2016 for public comment on this proposed permit. Comments must be
received by 5:00pm MT October 2, 2016, to be considered in the issuance of the final permit.
Please submit any written comments you may have concerning the terms and conditions of this permit. You
can send them directly to me at [email protected], or to [email protected]. Should the EPA not
accept any or all of these comments, you will be notified in writing and will be provided with the reasons for
not accepting them.
Thank you,
Colin C. Schwartz
Environmental Scientist
Air Permits Division
US EPA Region 8- Denver, CO
303-312-6043
Tribal Minor New Source
Review in Indian Country
United States Environmental
Protection Agency
Region 8
Air Program
1595 Wynkoop Street
Denver, CO 80202
Phone 800-227-8917
https://www.epa.gov/caa-
permitting/tribal-nsr-
permits-region-8
Proposed Air Quality Permit to Construct
Questar Pipeline Company
Fidlar Compressor Station
Notice issued: September 2, 2016
Written comments due:
5 p.m., October 2, 2016
Where is the facility located?
Fidlar Compressor Station: Uintah and
Ouray Indian Reservation
Uintah County, Utah
SW/NW Sec. 16, NW/NW Sec. 32,
NE/NE Sec. 3, T9S, R22E
Latitude 40.039722 N
Longitude -109.456944W
What is being proposed?
This permit action will apply to an
existing facility operating on the Uintah
and Ouray Indian Reservation in Utah.
The Fidlar Compressor Station is a natural
gas transmission compressor station
designed to boost pipeline pressure on
four transmission pipelines that flow
north, east, and west from the station
designed to compress and dehydrate a
comingled liquid stream received from
nearby field production wells.
Questar Pipeline Company (QPC)
currently holds a Federal operating permit
issued by the United States Environmental
Protection Agency, pursuant to the Title V
Operating Permit Program at 40 CFR part
71 (Part 71). The permit contains
emission limits created by the EPA. The
creation the emission limits in Part 71
permits was a temporary, gap-filling
measure for those sources operating in
Indian country that did not have the ability
to obtain these limits through pre-
construction permitting programs, such as
exists in state jurisdictions.
Upon promulgation of the Tribal Minor
New Source Review (MNSR) Program at
40 CFR part 49, it became necessary to
transfer these limits to the appropriate
MNSR permit.
The facility currently operates two natural
gas-fired turbines and two (2) 4-stroke
rich-burn (4SRB) reciprocating internal
combustion engines to compress and
boost the pressure of pipeline natural gas
from the four interstate pipelines.
QPC has requested enforceable limits on
nitrogen oxide (NOX) emissions for one of
the 4SRB compressor engines. QPC
operates a non-selective catalytic
reduction (NSCR) system and air-to-fuel
ratio (AFR) controller on the engine to
control emissions in compliance with
control requirements originally
established in a July 12, 2011 Part 71
operating permit The permit the EPA is
proposing to issue reflects the
incorporation of the requested
requirements, which are based on the
requirements in the Part 71 permit.
What are the effects on air quality?
This action will have no adverse air
quality impacts. The emissions at this
existing facility will not be increasing due
to this permit action. In addition, this
action does not authorize the construction
of any new emission sources, or emission
increases from existing sources, nor does
it otherwise authorize any other physical
modifications to the facility or its
operations.
Where can I send comments? EPA accepts comments by mail, fax and
e-mail.
US EPA Region 8 Air Program, 8P-AR
Attn: Federal Minor NSR Coordinator
1595 Wynkoop Street,
Denver, CO 80202
Fax: 303-312-6064
How can I review documents? You can review a paper or electronic copy
of the proposed permits and related
documents at the following locations:
Ute Indian Tribe Energy and Minerals
Department Office
988 South 7500 East, Annex Building
Fort Duchesne, Utah 84026
Contact: Minnie Grant, Air Coordinator,
at (435) 725-4900
US EPA Region 8 Office:
1595 Wynkoop Street, Denver, CO 80202
Hours: Mon-Fri 8:00 a.m. – 5:00 p.m.
Contact: Colin Schwartz, Environmental
Scientist, at 303-312-6043
US EPA Region 8 Website:
https://www.epa.gov/caa-permitting/caa-
permit-public-comment-opportunities-
region-8
Permit number:
SMNSR-UO-000002-2013.001
What happens next? The EPA will review and consider all
comments received during the comment
period. Following this review, the EPA
may issue the permits as proposed, issue
modified permits based on comments, or
deny the permits.
Public Notice: Request For Comments
United States Environmental Protection Agency
Region 8 Air Program
1595 Wynkoop Street
Denver, CO 80202
Air Pollution Control
Synthetic Minor Source Permit to Construct
40 CFR 49.151
# SMNSR-UO-000002-2013.001
Permit to Construct to establish legally and practically enforceable
limitations and requirements on sources at an existing facility
Permittee:
Questar Pipeline Company
Permitted Facility:
Fidlar Compressor Station
Uintah and Ouray Indian Reservation
Uintah County, Utah
2
Summary
On November 1, 2013, the EPA received an application from Questar Pipeline Company (QPC)
requesting a synthetic minor permit for the Fidlar Compressor Station in accordance with the
requirements of the Tribal Minor New Source Review (MNSR) Permit Program at 40 CFR part 49.
This proposed permit action applies to an existing facility operating on the Uintah and Ouray Indian
Reservation in Utah. This proposed permit would not authorize the construction of any new emission
sources, or emission increases from existing units nor would it otherwise authorize any other physical
modifications to the facility or its operations. This permit is only intended to incorporate required and
requested enforceable emission limits and operational restrictions from a July 15, 2011 operating permit
issued in accordance with the Title V Operating Permit Program at 40 CFR part 71 (Part 71). The permit
established emission limits for one (1) of the four (4) compressor engines operating at the station, a
1,061 horsepower (hp) spark ignition 4-stroke rich-burn (4SRB) natural gas-fired reciprocating internal
combustion engine used for natural gas compression.
The proposed MNSR permit reflects the incorporation of requirements created in the Part 71 permit
issued by the EPA at the request of QPC to recognize an emission control system that was voluntarily
installed and operated on the engine. The Part 71 permit contains conditions to limit nitrogen oxides
(NOX) from the 1,061 hp 4SRB compressor engine installed and operating at the facility. In addition,
associated testing, monitoring, recordkeeping and reporting requirements were established in order to
ensure that the limits were legally and practically enforceable.
The creation of the legally and practically enforceable limits in a Part 71 permit was a temporary, gap-
filling measure for those sources operating in Indian country that did not have the ability to obtain these
limits through other programs, such as exists in state jurisdictions.
Section 49.153(a)(3)(iv) of the MNSR regulation provides us with the authority to transfer such limits to
a MNSR permit, effectively creating legally and practically enforceable requirements without the use of
the emission limits in the Part 71 permit. The regulations at §§ 49.158(c)(2)(ii) and (iii) also provide us
with the discretion to require any additional requirements necessary to protect the National Ambient Air
Quality Standards (NAAQS), including monitoring and testing requirements, based on the specific
circumstances of the source. The EPA is proposing some additional requirements in accordance with
this provision.
Upon compliance with this permit, QPC will have legally and practically enforceable restrictions on
emissions that can be used when determining the applicability of other Clean Air Act (CAA) permitting
requirements, such as under the Prevention of Significant Deterioration (PSD) Permit Program at
40 CFR part 52 and the Part 71 Permit Program.
The EPA has determined that issuance of this MNSR permit will not contribute to NAAQS violations,
or have potentially adverse effects on ambient air quality.
3
Table of Contents
I. Conditional Permit to Construct......................................................................................................... 4
A. General Information .............................................................................................................................. 4
B. Applicability .......................................................................................................................................... 4
C. Requirements for Engines ..................................................................................................................... 4
D. Requirements for Records Retention .................................................................................................. 11
E. Requirements for Reporting ................................................................................................................ 11
II. General Provisions ............................................................................................................................ 13
A. Conditional Approval ...........................................................................................................................13
B. Authorization ....................................................................................................................................... 15
4
I. Conditional Permit to Construct
A. General Information
Facility: Questar Pipeline Company - Fidlar Compressor
Station
Permit number: SMNSR-UO-000002-2013.001
SIC Code and SIC Description: 4922 – Natural Gas Transmission
Site Location: Corporate Office Location
Fidlar Compressor Station Questar Pipeline Company
SW ¼, NW ¼ Sec 16 T9S R22E DNR 206, P.O. Box 45360
Uintah and Ouray Indian Reservation Salt Lake City, Utah 84145
Uintah County, Utah
Latitude 40.039722, Longitude -109.456944
The equipment listed in this permit shall be operated by Questar Pipeline Company at the location
described above.
B. Applicability
1. This permit to construct is being issued under authority of the MNSR Permit Program.
2. The requirements in this permit have been created, at the Permittee’s request, to establish legally
and practically enforceable restrictions for limiting NOX engine emissions.
3. Any conditions established for this facility or any specific units at this facility pursuant to any
permit issued under the authority of the PSD Permit Program or the MNSR Permit Program shall
continue to apply.
4. By issuing this permit, EPA does not assume any risk of loss which may occur as a result of the
operation of the permitted facility by the Permittee, Owner and/or Operator, if the conditions of
this permit are not met by the Permittee, Owner and/or Operator.
C. Requirements for Engines
1. Construction and Operational Limits
(a) The Permittee shall install, operate and maintain emission controls as specified in this
permit on one (1) reciprocating internal combustion engine used for compression,
meeting the following specifications:
(i) Operated as a 4-stroke rich-burn (4SRB) engine;
(ii) Fired with natural gas; and
(iii) Limited to a maximum site rating of 1,061 site rated (hp).
(b) Only the engine that is operated and controlled as specified in this permit is approved for
installation under this permit.
5
2. Emission Limits
(a) NOX emissions from the 1,061 hp 4SRB engine shall not exceed:
(i) 4.68 pounds per hour (lb/hr); and
(ii) 2.0 grams per horsepower-hour (g/hp-hr).
(b) Emission limits specified in this permit shall apply at all times unless otherwise specified
in this permit.
3. Control and Operational Requirements
(a) The Permittee shall ensure that the 1,061 hp 4SRB engine is equipped with an air-to-fuel
ratio (AFR) control system and a non-selective catalytic reduction (NSCR) system
capable of reducing uncontrolled NOX emissions to meet the emission limits specified in
this permit.
(b) The Permittee shall replace the oxygen (O2) sensor on the AFR controller on the 1,061 hp
4SRB engine within every 2,190 hours of engine run time.
(d) The Permittee shall install, operate and maintain a temperature-sensing device (i.e.,
thermocouple or resistance temperature detectors) before the NSCR control system to
continuously monitor the exhaust temperature at the inlet of the NSCR control system.
The temperature-sensing device shall be calibrated and operated by the Permittee
according to manufacturer specifications or equivalent specifications developed by the
Permittee or vendor. The temperature-sensing device shall be accurate to within 0.75% of
span.
(e) Except during startups, which shall not exceed 30 minutes, the engine exhaust
temperature at the inlet to the NSCR control system shall be maintained and at all times
the engine operates in accordance with the NSCR manufacturer’s specifications for
optimum performance.
(f) During operation, the pressure drop across the NSCR control system on the engine shall
be maintained to within ±2 inches of water from the baseline pressure drop measured
during the most recent performance test. The baseline pressure drop across the NSCR
control system shall be determined at 100% ± 10% of the engine load measured during
the most recent performance test.
(g) The Permittee shall only fire the engine with natural gas. The natural gas shall be pipeline
quality in all respects except that the carbon dioxide (CO2) concentration in the gas is not
required to be within pipeline quality.
(h) The Permittee shall follow, for the engine and respective NSCR control system, the
manufacturer recommended maintenance schedule and procedures, or equivalent
maintenance schedule and procedures developed by the Permittee or vendor, to ensure
optimum performance of the engine and its respective catalytic control system.
6
(i) The Permittee may rebuild or replace an existing permitted engine with an engine of the
same horsepower rating, and configured to operate in the same manner as the engine
being rebuilt or replaced. Any emission limits, requirements, control technologies, testing
or other provisions that apply to the permitted engine that are replaced shall also apply to
the rebuilt or replacement engine.
(j) The Permittee may resume operation without the NSCR control system during an engine
break-in period, not to exceed 200 operating hours, for rebuilt and replacement engines.
4. Performance Testing Requirements
(a) Performance tests shall be conducted on the 1,061 hp 4SRB engine for measuring NOX
emissions to demonstrate compliance with each emission limitation in this permit. The
performance tests shall be conducted in accordance with appropriate reference methods
specified in 40 CFR part 60, Appendix A and 40 CFR part 63, Appendix A or an EPA
approved American Society for Testing and Materials (ASTM) method. The Permittee
may submit to the EPA a written request for approval of an alternate test method, but
shall only use that alternate test method after obtaining approval from the EPA.
(i) An initial performance test shall be conducted within 45 calendar days of the
effective date of this permit.
(ii) Subsequent performance tests shall be conducted within 12 consecutive months
after the most recent performance test.
(iii) Performance tests shall be conducted within 45 calendar days of startup of the
engine after cleaning or replacement of the NSCR control system catalyst.
(iv) Performance tests shall be conducted within 45 calendar days of startup of each
rebuilt or replaced engine.
(b) The Permittee shall not perform engine tuning or make any adjustments to engine
settings, NSCR control system settings, processes or operational parameters the day of or
during the engine testing. Any such tuning or adjustments may result in a determination
by the EPA that the test is invalid. Artificially increasing an engine load to meet test
requirements is not considered engine tuning or adjustments.
(c) The Permittee shall not abort any engine tests that demonstrate non-compliance with any
NOX emission limits in this permit.
(d) Performance tests conducted on the 1,061 hp 4SRB engine for measuring NOX emissions
shall meet the following requirements:
(i) The pressure drop across the NSCR control system and the inlet temperature to
the NSCR control system shall be measured and recorded at least once per test
during all performance tests.
(ii) The Permittee shall measure CO emissions from the 1,061 hp 4SRB engine
simultaneously with all performance tests for NOX emissions. CO emissions shall
be measured using a portable analyzer and protocol approved in writing by the
EPA. [Note to Permittee: Although the permit does not contain CO emission
limits for this engine, NOX measurement requirements have been included as an
7
indicator to ensure compliance with Condition C.4(b) above.]
(iii) All performance tests shall be conducted at maximum operating rate (90% to
110% of the maximum achievable load available at the time of the test). The
Permittee may submit to the EPA a written request for approval of an alternate
load level for testing, but shall only test at that alternate load level after obtaining
written approval from the EPA.
(iv) During each test run, data shall be collected on all parameters necessary to
document how emissions were measured and calculated (such as test run length,
minimum sample volume, volumetric flow rate, moisture and oxygen corrections,
etc.).
(v) Each test shall consist of at least three 1 hour or longer valid test runs. Emission
results shall be reported as the arithmetic average of all valid test runs and shall be
in terms of the emission limits in this permit.
(vi) A performance test plan shall be submitted to the EPA for approval within 30
calendar days of the effective date of this permit.
(vii) Performance test plans that have already been approved by the EPA for the
emission unit approved in this permit may be used in lieu of new test plans unless
the EPA requires the submittal and approval of new test plans. The Permittee may
submit new plans for EPA approval at any time.
(viii) The test plans shall include and address the following elements:
(A) Purpose of the test;
(B) Engine and NSCR control system to be tested;
(C) Expected engine operating rate during the test;
(D) Sampling and analysis procedures (sampling locations, test methods,
laboratory identification);
(E) Quality assurance plan (calibration procedures and frequency, sample
recovery and field documentation, chain of custody procedures); and
(F) Data processing and reporting (description of data handling and quality
control procedures, report content).
(e) The Permittee shall notify the EPA at least 30 calendar days prior to scheduled
performance testing. The Permittee shall notify the EPA at least 1 week prior to
scheduled performance testing if the testing cannot be performed.
(f) If the results of a complete and valid performance test of the emissions from the
permitted engine demonstrate noncompliance with the emission limits in this permit, the
engine shall be shut down as soon as safely possible and appropriate corrective action
shall be taken (e.g., repairs, catalyst cleaning, catalyst replacement). The Permittee shall
notify the EPA in writing within 24 hours of each such shut down. The engine must be
retested within 7 days of being restarted and the emissions must meet the applicable
limits in this permit. If the retest shows that the emissions continue to exceed the limits in
this permit, the engine shall again be shut down as soon as safely possible, and the engine
8
may not operate, except for purposes of startup and testing, until the Permittee
demonstrates through testing that the emissions do not exceed the emission limits in this
permit.
(g) If a permitted engine is not operating, the Permittee does not need to start up the engine
solely to conduct a performance test. The Permittee may conduct the performance test
when the engine is started up again.
5. Monitoring Requirements
(a) The Permittee shall continuously measure the engine exhaust temperature at the inlet to
the NSCR control system at all times the engine operates.
(b) Except during startups, which shall not exceed 30 minutes, if the engine’s exhaust
temperature at the inlet to the NSCR control system deviates from the acceptable range
specified by the manufacturer then the following actions shall be taken. The Permittee’s
completion of any or all of these actions shall not constitute, nor qualify as, an exemption
from the NOX emission limits in this permit.
(i) Within 24 hours of determining a deviation of the engine exhaust temperature at
the inlet to the NSCR control system, the Permittee shall investigate. The
investigation shall include testing the temperature sensing device, inspecting the
engine for performance problems and assessing the NSCR control system for
possible damage that could affect NSCR control system effectiveness (including,
but not limited to, catalyst housing damage and fouled, destroyed or poisoned
catalyst).
(ii) If the engine exhaust temperature at the inlet to the NSCR control system can be
corrected by following the engine manufacturer recommended procedures or
equivalent procedures developed by the Permittee or vendor and the NSCR
control system has not been damaged, then the Permittee shall correct the engine
exhaust temperature at the inlet to the NSCR control system within 24 hours of
inspecting the engine and NSCR control system.
(iii) If the engine exhaust temperature at the inlet to the NSCR control system cannot
be corrected using the engine manufacturer recommended procedures or
equivalent procedures developed by the Permittee or vendor, or the NSCR control
system has been damaged, then the affected engine shall cease operating
immediately and shall not be returned to routine service until the following has
been met:
(A) The engine exhaust temperature at the inlet to the NSCR control system is
measured and found to be within the acceptable temperature range for that
engine; and
(B) The NSCR control system has been repaired or replaced, if necessary.
(c) The Permittee shall monitor the pressure drop across the NSCR control system on the
engine at least once every hour that the engine operates, beginning with the effective day
of this permit, using pressure sensing devices before and after the NSCR control system
to obtain a direct reading of the pressure drop (also referred to as the differential
pressure). [Note to Permittee: Differential pressure measurements, in general, are used
9
to show the pressure across the filter elements. This information will determine when the
elements in the NSCR control system are fouling, blocked or blown out and thus require
cleaning or replacement.]
(d) If the pressure drop reading exceeds ± 2 inches of water from the baseline pressure drop
reading taken during the most recent performance test, then the following actions shall be
taken. The Permittee’s completion of any or all of these actions shall not constitute, nor
qualify as, an exemption from any other emission limits in this permit:
(i) Within 24 hours of determining a deviation of the pressure drop across the NSCR
control system, the Permittee shall investigate. The investigation shall include
testing the pressure transducers and assessing the NSCR control system for
possible damage that could affect catalytic system effectiveness (including, but
not limited to, catalyst housing damage and plugged, fouled, destroyed or
poisoned catalyst).
(ii) If the pressure drop across the NSCR control system can be corrected by
following the NSCR control system manufacturer recommended procedures or
equivalent procedures developed by the Permittee or vendor, and the NSCR
control system has not been damaged, then the Permittee shall correct the problem
within 24 hours of inspecting the NSCR control system.
(iii) If the pressure drop across the NSCR control system cannot be corrected using the
NSCR control system manufacturer recommended procedures or equivalent
procedures developed by the Permittee or vendor, or the NSCR control system is
damaged, then the Permittee shall do one of the following:
(A) Conduct a performance test within 45 calendar days, as specified in this
permit, to ensure that the emission limits are being met and to re-establish
the pressure drop across the NSCR control system. The Permittee shall
perform a portable analyzer test for CO and NOX to establish a new
temporary pressure drop baseline until a performance test can be
scheduled and completed; or
(B) Cease operating the affected engine immediately. The engine shall not be
returned to routine service until the pressure drop is measured and found
to be within the acceptable pressure range for that engine as determined
from the most recent performance test. Corrective action may include
removal and cleaning of the catalyst or replacement of the catalyst.
(e) The Permittee shall monitor NOX and CO emissions from the exhaust of the NSCR
control system on the engine at least quarterly to demonstrate compliance with the
engines NOX emission limits in this permit. To meet this requirement, the Permittee shall:
(i) Measure NOX and CO emissions at the normal operating load using a portable
analyzer and a monitoring protocol approved by the EPA or conduct a
performance test as specified in this permit;
(ii) Measure the NOX and CO emissions simultaneously; and
(iii) Commence monitoring for NOX and CO emissions within 45 calendar days of the
Permittee’s submittal of the initial performance test results for NOX emissions, as
appropriate, to the EPA.
10
(f) The Permittee shall not perform engine tuning or make any adjustments to engine
settings, NSCR control system settings, processes or operational parameters the day of or
during measurements. Any such tuning or adjustments may result in a determination by
the EPA that the result is invalid. Artificially increasing an engine load to meet
monitoring requirements is not considered engine tuning or adjustments.
(g) If the results of 2 consecutive quarterly portable analyzer measurements demonstrate
compliance with NOX emission limits, the required monitoring frequency may change
from quarterly to semi-annually.
(h) If the results of any semi-annual portable analyzer measurement demonstrates non-
compliance with the NOX emission limits, the required test frequency shall revert back to
quarterly.
(i) The Permittee shall submit portable analyzer specifications and NOX and CO monitoring
protocols to the EPA at the following address for approval at least 45 calendar days prior
to the date of initial portable analyzer monitoring:
U.S. Environmental Protection Agency, Region 8
Office of Enforcement, Compliance & Environmental Justice
Air Toxics and Technical Enforcement Program, 8ENF-AT
1595 Wynkoop Street
Denver, Colorado 80202
(j) Portable analyzer specifications and monitoring protocols that have already been
approved by the EPA for the emission units approved in this permit may be used in lieu
of new protocols unless the EPA determines it is necessary to require the submittal and
approval of a new protocol. The Permittee may submit a new protocol for EPA approval
at any time.
(k) The Permittee is not required to conduct emissions monitoring and parametric monitoring
of exhaust temperature and NSCR control system differential pressure on the engine if it
has not operated during the monitoring period. The Permittee shall certify that the engine
did not operate during the monitoring period in the annual report specified in Condition
I.E.1.
6. Recordkeeping Requirements
(a) Records shall be kept of manufacturer and/or vendor specifications and maintenance
requirements developed by the manufacturer, vendor or Permittee for the engine, AFR
control system, NSCR control system, temperature-sensing device and pressure-
measuring devices.
(b) Records shall be kept of all calibration and maintenance conducted for the engine,
catalytic control system, temperature-sensing device and pressure-measuring device.
(c) Records shall be kept that are sufficient to demonstrate that the fuel for the engine is
pipeline quality natural gas in all respects, with the exception of CO2 concentrations.
11
(d) Records shall be kept of all temperature measurements required in this permit, as well as
a description of any corrective actions taken pursuant to this permit.
(e) Records shall be kept of all pressure drop measurements required in this permit, as well
as a description of any corrective actions taken pursuant to this permit.
(f) Records shall be kept of all required testing and monitoring in this permit. The records
shall include the following:
(i) The date, place, and time of sampling or measurements;
(ii) The dates analyses were performed;
(iii) The company or entity that performed the analyses;
(iv) The analytical techniques or methods used;
(v) The results of such analyses or measurements; and
(vi) The operating conditions as existing at the time of sampling or measurement.
(g) Records shall be kept of all NSCR control system catalyst replacements or repairs, AFR
control system replacements, engine rebuilds and replacements.
(h) Records shall be kept of each rebuilt or replacement engine break-in period, pursuant to
the requirements of this permit, where an existing engine that has been rebuilt or replaced
resumes operation without the NSCR control system, for a period not to exceed 200
hours.
(i) Records shall be kept of each time the engine is shut down due to a deviation in the inlet
temperature to the NSCR control system or pressure drop across a NSCR control system.
The Permittee shall include in the record the cause of the problem, the corrective action
taken and the timeframe for bringing the pressure drop and inlet temperature range into
compliance.
D. Requirements for Records Retention
1. The Permittee shall retain all records required by this permit for a period of at least 5 years from
the date the record was created.
2. Records shall be kept in the vicinity of the facility, such as at the facility, the location that has
day-to-day operational control over the facility or the location that has day-to-day responsibility
for compliance of the facility.
E. Requirements for Reporting
1. Annual Emission Reports
(a) The Permittee shall submit a written annual report of the actual annual emissions from
the 1,061 hp 4SRB engine each year no later than April 1st. The annual report shall cover
the period for the previous calendar year. All reports shall be certified to truth and
accuracy by the responsible official.
12
(b) The report shall include NOX emissions.
(c) The report shall be submitted to:
U.S. Environmental Protection Agency, Region 8
Office of Partnerships and Regulatory Assistance
Tribal Air Permitting Program, 8P-AR
1595 Wynkoop Street
Denver, Colorado 80202
The report may be submitted via electronic mail to [email protected].
2. All other documents required to be submitted under this permit, with the exception of the Annual
Emission Reports, shall be submitted to:
U.S. Environmental Protection Agency, Region 8
Office of Enforcement, Compliance & Environmental Justice
Air Toxics and Technical Enforcement Program, 8ENF-AT
1595 Wynkoop Street
Denver, Colorado 80202
Documents may be submitted via electronic mail to [email protected].
3. The Permittee shall promptly submit to the EPA a written report of any deviations of emission or
operational limits specified in this permit and a description of any corrective actions or
preventative measures taken. A “prompt” deviation report is one that is post marked or submitted
via electronic mail to [email protected] as follows:
(a) Within 30 days from the discovery of a deviation that would cause the Permittee to
exceed the emission limits or operational limits if left un-corrected for more than 5 days
after discovering the deviation; and
(b) By April 1st for the discovery of a deviation of recordkeeping or other permit conditions
during the preceding calendar year that do not affect the Permittee’s ability to meet the
emission limits.
4. The Permittee shall submit a written report for any required performance tests to the EPA
Regional Office within 60 days after completing the tests.
5. The Permittee shall submit any record or report required by this permit upon EPA request.
13
II. General Provisions
A. Conditional Approval
Pursuant to the authority of 40 CFR 49.151, the EPA hereby conditionally grants this permit to
construct. This authorization is expressly conditioned as follows:
1. Document Retention and Availability: This permit and any required attachments shall be retained
and made available for inspection upon request at the location set forth herein.
2. Permit Application: The Permittee shall abide by all representations, statements of intent and
agreements contained in the application submitted by the Permittee. The EPA shall be notified
10 days in advance of any significant deviation from this permit application as well as any plans,
specifications or supporting data furnished.
3. Permit Deviations: The issuance of this permit may be suspended or revoked if the EPA
determines that a significant deviation from the permit application, specifications and supporting
data furnished has been or is to be made. If the proposed source is constructed, operated or
modified not in accordance with the terms of this permit, the Permittee will be subject to
appropriate enforcement action.
4. Compliance with Permit: The Permittee shall comply with all conditions of this permit, including
emission limitations that apply to the affected emissions units at the permitted facility/source.
Noncompliance with any permit term or condition is a violation of this permit and may constitute
a violation of the CAA and is grounds for enforcement action and for a permit termination or
revocation.
5. Fugitive Emissions: The Permittee shall take all reasonable precautions to prevent and/or
minimize fugitive emissions during the construction period.
6. NAAQS and PSD Increments: The permitted source shall not cause or contribute to a NAAQS
violation or a PSD increment violation.
7. Compliance with Federal and Tribal Rules, Regulations, and Orders: Issuance of this permit
does not relieve the Permittee of the responsibility to comply fully with all other applicable
federal and tribal rules, regulations and orders now or hereafter in effect.
8. Enforcement: It is not a defense, for the Permittee, in an enforcement action, to claim that it
would have been necessary to halt or reduce the permitted activity in order to maintain
compliance with the conditions of this permit.
9. Modifications of Existing Emissions Units/Limits: For proposed modifications, as defined at
40 CFR 49.152(d), that would increase an emissions unit allowable emissions of pollutants
above its existing permitted annual allowable emissions limit, the Permittee shall first obtain a
permit modification pursuant to the MNSR regulations approving the increase. For a proposed
modification that is not otherwise subject to review under the PSD or MNSR regulations, such
proposed increase in the annual allowable emissions limit shall be approved through an
administrative permit revision as provided at 40 CFR 49.159(f).
14
10. Relaxation of Legally and Practically Enforceable Limits: At such time that a new or modified
source within this permitted facility/source or modification of this permitted facility/source
becomes a major stationary source or major modification solely by virtue of a relaxation in any
legally and practically enforceable limitation which was established after August 7, 1980, on the
capacity of the permitted facility/source to otherwise emit a pollutant, such as a restriction on
hours of operation, then the requirements of the PSD regulations shall apply to the source or
modification as though construction had not yet commenced on the source or modification.
11. Revise, Reopen, Revoke and Reissue, or Terminate for Cause: This permit may be revised,
reopened, revoked and reissued or terminated for cause. The filing of a request by the Permittee
for a permit revision, revocation and reissuance, termination or of a notification of planned
changes or anticipated noncompliance does not stay any permit condition. The EPA may reopen
this permit for a cause on its own initiative, e.g., if this permit contains a material mistake or the
Permittee fails to assure compliance with the applicable requirements.
12. Severability Clause: The provisions of this permit are severable, and in the event of any
challenge to any portion of this permit, or if any portion is held invalid, the remaining permit
conditions shall remain valid and in force.
13. Property Rights: This permit does not convey any property rights of any sort or any exclusive
privilege.
14. Information Requests: The Permittee shall furnish to the EPA, within a reasonable time, any
information that the EPA may request in writing to determine whether cause exists for revising,
revoking and reissuing, terminating or determining compliance with this permit. For any such
information claimed to be confidential, the Permittee shall also submit a claim of confidentiality
in accordance with 40 CFR part 2, subpart B.
15. Inspection and Entry: The EPA or its authorized representatives may inspect this permitted
facility/source during normal business hours for the purpose of ascertaining compliance with all
conditions of this permit. Upon presentation of proper credentials, the Permittee shall allow the
EPA or its authorized representative to:
(a) Enter upon the premises where this permitted facility/source is located or emissions-
related activity is conducted or where records are required to be kept under the conditions
of this permit;
(b) Have access to and copy, at reasonable times, any records that are required to be kept
under the conditions of this permit;
(c) Inspect, during normal business hours or while this permitted facility/source is in
operation, any facilities, equipment (including monitoring and air pollution control
equipment), practices or operations regulated or required under this permit;
(d) Sample or monitor, at reasonable times, substances or parameters for the purpose of
assuring compliance with this permit or other applicable requirements; and
(e) Record any inspection by use of written, electronic, magnetic and photographic media.
15
16. Permit Effective Date: This permit is effective immediately upon issuance unless comments
resulted in a change in the proposed permit, in which case the permit is effective 30 days after
issuance. The Permittee may notify the EPA, in writing, that this permit or a term or condition of
it is rejected. Such notice should be made within 30 days of receipt of this permit and should
include the reason or reasons for rejection.
17. Permit Transfers: Permit transfers shall be made in accordance with 40 CFR 49.159(f). The Air
Program Director shall be notified in writing at the following address if the company is sold or
changes its name:
U.S. Environmental Protection Agency, Region 8
Office of Partnerships and Regulatory Assistance
Tribal Air Permitting Program, 8P-AR
1595 Wynkoop Street
Denver, Colorado 80202
18. Invalidation of Permit: Unless this permitted source of emissions is an existing source, this
permit becomes invalid if construction is not commenced within 18 months after the effective
date of this permit, construction is discontinued for 18 months or more or construction is not
completed within a reasonable time. The EPA may extend the 18 month period upon a
satisfactory showing that an extension is justified. This provision does not apply to the time
period between the constructions of the approved phases of a phased construction project. The
Permittee shall commence construction of each such phase within 18 months of the projected and
approved commencement date.
19. Notification of Start-Up: The Permittee shall submit a notification of the anticipated date of
initial start-up of this permitted source to the EPA within 60 days of such date, unless this
permitted source of emissions is an existing source.
B. Authorization
Authorized by the United States Environmental Protection Agency, Region 8
Monica Morales Date
Acting Director
Air Program
United States Environmental Protection Agency
Region 8 Air Program
Air Pollution Control Synthetic Minor Source Permit to Construct
Technical Support Document for
Proposed Permit #SMNSR-UO-000002-2013.001
Questar Pipeline Company
Fidlar Compressor Station
Uintah and Ouray Indian Reservation
Uintah County, Utah
In accordance with the requirements of the Tribal Minor New Source Review (MNSR) Permit Program
at 40 CFR part 49, this federal permit to construct is being issued under authority of the Clean Air Act
(CAA). The EPA has prepared this technical support document describing the conditions of this permit
and presents information that is germane to this permit action.
2
Table of Contents
I. Introduction .................................................................................................................................... 3
II. Facility Description ........................................................................................................................ 4
III. Proposed Synthetic Minor Permit Action ...................................................................................... 7
IV. Air Quality Review ........................................................................................................................ 9
V. Tribal Consultations and Communications .................................................................................... 9
VI. Environmental Justice .................................................................................................................. 10
VII. Authority ...................................................................................................................................... 11
VIII. Public Notice ................................................................................................................................ 12
3
I. Introduction
On November 1, 2013, we received an application from Questar Pipeline Company (QPC), requesting a
synthetic minor permit for the Fidlar Compressor Station in accordance with the requirements of the
MNSR Permit Program.
This proposed permit action applies to an existing facility operating on the Uintah and Ouray Indian
Reservation in Utah.
This proposed permit would not authorize the construction of any new emission sources, or emission
increases from existing units, nor would it otherwise authorize any other physical modifications to the
facility or its operations. This permit is only intended to incorporate required and requested emission
limits and provisions from the following documents:
A. On July 15, 2011, we issued an operating permit to QPC for the Fidlar Compressor
Station in accordance with the Title V Operating Permit Program at 40 CFR part 71 (Part 71).
The permit established emission limits for one (1) of the four (4) compressor engines operating
at the station, a 1,061 horsepower (hp) spark ignition 4-stroke rich-burn (4SRB) natural gas-fired
reciprocating internal combustion engine used for natural gas compression.
The proposed MNSR permit reflects the incorporation of requirements created in the Part 71
permit issued by the EPA at the request of QPC. QPC requested these requirements to recognize
an emission control system that was voluntarily installed and operated on the engine. The Part 71
permit contains conditions to limit nitrogen oxides (NOX) from the 1,061 hp 4SRB compressor
engine installed and operating at the facility. In addition, associated testing, monitoring,
recordkeeping, and reporting requirements were established in order to ensure that the limits
were legally and practically enforceable.
The creation of the legally and practically enforceable limits in a Part 71 permit was a temporary,
gap-filling measure for those sources operating in Indian country that did not have the ability to
obtain these limits through other programs, such as exists in state jurisdictions.
Section 49.153(a)(3)(iv) of the MNSR regulation provides us with the authority to transfer such
limits to a MNSR permit, effectively creating legally and practically enforceable requirements
without the use of the emission limits in the Part 71 permit. The regulations at
§§49.158(c)(2)(ii) and (iii) also provide us with the discretion to require any additional
requirements necessary to protect the National Ambient Air Quality Standards, including
monitoring and testing requirements, based on the specific circumstances of the source.
B. We received an application from QPC requesting a synthetic minor MNSR permit for the Fidlar
Compressor Station on November 1, 2013.
The application contained a request to transfer the limits on the 1,061 hp 4SRB compressor
engine that were established in the Part 71 permit issued on July 15, 2011. This proposed permit
reflects the incorporation of NOX emission limits on the engine. These proposed limits, if made
legally and practically enforceable, would allow QPC to use the controlled NOX emission rates in
determining potential to emit and applicability of other CAA requirements, such as the
Prevention of Significant Deterioration (PSD), MNSR and Part 71 Permit Programs.
4
Upon compliance with this permit, QPC will have maintained legally and practically enforceable
requirements to reduce emissions that can be accounted for when determining the applicability of other
CAA requirements, such as permitting requirements under the PSD Permit Program and the Part 71
Permit Program.
II. Facility Description
Process Description
The Fidlar Compressor Station is a natural gas transmission compressor station capable of boosting
pipeline pressure on four transmission pipelines owned and operated by QPC that flow north, east, and
west from the station. The 4SRB compressor engine for which QPC is requesting enforceable emissions
limitations under the MNSR Permit Program is one of four (4) compressor engines operating at the
station. The 4SRB compressor engine proposed to be permitted is capable of compressing natural gas by
drawing gas from the Fidlar Compressor Station suction piping header, mechanically compressing the
gas in a piston, and discharging the gas to the discharge piping header. Since the gas heats up during
compression, the gas may flow through a discharge gas cooler before flowing back into a transmission
pipeline. The discharge gas cooler is a simple process whereby fans circulate ambient air across fins
containing the pressurized gas. Heat from the process is radiated to atmosphere. There is no contact
between the gas and the air; the pressurized gas simply flows through the cooler before being discharged
to the transmission pipeline. A fuel gas system routes gas from the natural gas pipeline to the engine for
combustion. Mechanical work created in the engine drives the compressor pistons.
Source Description
The MNSR Permit Program at Section 49.152(d) defines synthetic minor source as a source that
otherwise has the potential to emit regulated NSR pollutants in amounts that are at or above those for
major sources in §49.167, §52.21 or §71.2 of that chapter, as applicable, but that has taken a restriction
so that its potential to emit is less than such amounts for major sources. The Fidlar Compressor Station
took such restrictions as originally established in the Part 71 permit issued prior to promulgation of the
MNSR Permit Program. The PSD Permit Program and the Part 71 permit program identify regulatory
criteria for identifying emissions activities that belong to the same "building," "structure," "facility," or
"installation” (the source) to determine applicability to CAA stationary source permitting requirements.
These criteria are: (1) whether the activities are under the control of the same person (or person under
common control); (2) whether the activities are located on one or more contiguous or adjacent
properties; and (3) whether the activities belong to the same industrial grouping. [See
40 CFR 71.2, and 40 CFR 52.21 (b)(6).]
On June 3, 2016, the EPA published a final rule clarifying when oil and natural gas sector equipment
and activities must be deemed a single source when determining whether major source permitting
programs (PSD and New Source Review preconstruction Permit Programs, and the Part 71 Permit
Program) apply (81 FR 35622). By defining the term “adjacent,” the rule specifies that equipment and
activities in the oil and natural gas sector that are under common control will be considered part of the
same source if they are located on the same surface site or on individual surface sites that share
equipment and are within ¼ mile of each other. The EPA had previously defined adjacent through policy
interpretation and guidance.
Information used to determine the source for the Fidlar Compressor Station came from QPC’s MNSR
permit application dated November 1, 2013, and QPC’s November 1, 2013 response¹ to an additional
5
information request from the EPA for the Part 71 Renewal application on July 11, 2013. The emission
units and activities listed on Table 1 in this Technical Support Document are all part of the stationary
source addressed by this permit action, as they meet all of the three criteria in the PSD and Part 71
regulations. All of the emission units and activities at the facility are under the common control of QPC,
provide natural gas compression and pipeline transmission under the same industrial grouping, Standard
Industrial Classification code 4922, and are located on one contiguous and adjacent property. There are
no air emission points owned and operated by QPC in the natural gas transmission industrial grouping
(SIC code 4922) within ¼ mile of the Fidlar Compressor Station that share equipment located at the
Fidlar Compressor Station (or vice versa). The nearest natural gas transmission facility owned and
operated by QPC is the Blind Canyon Compressor Station, located approximately 40 miles west of the
Fidlar Compressor Station in Utah. Additionally, all natural gas transmission pipelines and stations
owned and operated by QPC are capable of operating independently. Further, QPC does not own or
operate any natural gas production air emission components in the production industrial grouping (SIC
code 1311). The Fidlar Compressor Station can deliver/receive natural gas to/from two (2) third party
gas processing plants: the Chipeta Processing, LLC Chipeta Gas Plant, located approximately 2 miles
away; and the QEP Resources Stagecoach/Ironhorse Gas Processing Complex located approximately ¼
mile away. QPC can receive gas for transportation from both processing plants either through the Fidlar
Compressor Station or directly into the main transportation pipelines without passing through the
station. The preamble to the August 7, 1980 promulgation of the PSD regulations (45 FR 52676, pages
52694-95) discusses that the EPA does not intend a source to encompass activities that would be many
miles apart along a long-line operation. Consistent with this stated intent, the EPA determined that an
emission source 40 miles from the Fidlar Compressor Station with no intermediary emission points is
not contiguous or adjacent to the Fidlar Compressor Station. As there are no other emission points in the
same industrial grouping that are under the common control of QPC and located within ¼ mile of the
Fidlar Compressor Station, the EPA has determined that the Fidlar Compressor Station is not contiguous
or adjacent any other QPC owned and operated transmission compressor stations.
The emission units identified in Table 1 are currently installed and operating at the facility. The
information provided in this table is for informational purposes only and is not intended to be viewed as
enforceable restrictions or open for public comment. The units and control requirements identified here
either existed prior to any pre-construction permitting requirements or were approved/required through
the mechanism identified. Table 2, Facility-wide Emissions, provides an accounting of uncontrolled
emissions and controlled allowable emissions in tons per year (tpy).
6
Table 1. Existing Emission Units
Unit Description Controls Original Preconstruction &/or
Required Emissions Control Details
Two (2) 11.6 MMBtu/hr each, 1,019 hp each,
natural gas fired turbines for natural gas
compression.
None
No pre-construction approval required for the
installation of the turbines. Installed prior to
the promulgation of the MNSR Permit
Program.
Subject to the New Source Performance
Standards (NSPS) for Stationary Gas
Turbines at 40 CFR, part 60, subpart GG.
One (1) 37.05 MMBtu/hr, 4,028 hp, natural gas
fired turbine for natural gas compression. None
No pre-construction approval required for the
installation of the engine. Installed prior to the
promulgation of the MNSR Permit Program.
Subject to the New Source Performance
Standards (NSPS) for Stationary Gas
Turbines at 40 CFR, part 60, subpart GG.
One (1) 10.79 MMBtu/hr, 1,061 hp, natural gas
fired, 4SRB engine for natural gas compression AFR & NSCR
No pre-construction approval required for the
installation of the storage tanks. Installed
prior to the promulgation of the MNSR
Permit Program.
Control requirements established in the
July 15, 2011 Part 71 Significant Permit
Modification, Permit # V-UO-00002-05.01.
Control requirements requested and proposed
to be established through this MNSR permit
action.
One (1) 6.54 MMBtu/hr, 643 hp, natural gas fired
stand by 4SRB engine for emergency power
generation
AFR & NSCR
No pre-construction approval required for the
installation of the engine. Installed prior to the
promulgation of the MNSR Permit Program.
Subject to the New Source Performance
Standards for Stationary Spark Ignition
Internal Combustion Engines at 40 CFR part
60, subpart JJJJ.
One (1) 400 barrel condensate sludge storage tank,
42,000 gallons/year (gal/yr) throughput None
No pre-construction approval required for the
installation of the tank. Installed prior to the
promulgation of the MNSR Permit Program.
42,000 gal/yr condensate sludge tank truck loading
rack None
No pre-construction approval required for the
tank truck loading rack. Installed prior to the
promulgation of the MNSR Permit Program.
Fugitive Emissions from valves, seals, pumps, etc. None
No pre-construction approval required for the
fugitive emissions. Valves, seals, pumps, etc.,
installed prior to the promulgation of the
MNSR Permit Program.
Insignificant Emission Units:**
Maintenance cabinet, battery banks (2), natural gas fuel line
heater (0.75 MMBtu/hr), electric air compressor, two (2)
space heaters, two (2) diesel storage tanks (500 gal each),
natural gas building heat boiler (1.7 MMBtu/hr), bench
grinder, two (2) lubrication oil tanks (500 gal each),
ambitrol storage tank (678 gal), two (2) glycol storage tanks
(6,300 gal and 3,755 gal), compressor blowdown.
None
No pre-construction approval required for the
insignificant emission units. Installed prior to
the promulgation of the MNSR Permit
Program.
* bbl = barrel; MMBtu/hr = million British thermal units per hour; MMscfd = million standard cubic feet per day.
** As defined in 40 CFR 71.5(c)(11).
7
Table 2. Facility-wide Emissions
Pollutant
Uncontrolled
Emissions
(tpy)
Controlled
Allowable
Emissions
(tpy)
PM – Particulate Matter
PM10 – Particulate Matter less than 10
microns in size
PM2.5 – Particulate Matter less than 2.5
microns in size
SO2 – Sulfur Dioxide
NOX – Nitrogen Oxides
CO – Carbon Monoxide
VOC – Volatile Organic Compounds
CO2 – Carbon dioxide
CH4 – Methane
N2O – Nitrous oxide
HFCs – Hydrofluorocarbons
PFCs – Perfluorocarbons
SF6 – Sulfur hexafluoride
CO2e – Equivalent CO2. A measure used to
compare the emissions from various
greenhouse gases based upon their global
warming potential (GWP)
HFCs, PFCs, and SF6 emissions are not
created during oil and natural gas production
operations.
NA – Not Available
*For the purposes of this illustration, does not
account for the federally enforceable control
requirements established in the current
effective Part 71 permit and requested in this
proposed permit for the 1,061 hp 4SRB
compressor engine, but does account for
federally enforceable emissions control
standards that apply to other units at the
facility.
**Total HAPs is inclusive of, but not limited
to the individual HAPs listed above.
PM 2.90 2.90
PM10 2.90 2.90
PM2.5 2.90 2.90
SO2 0.45 0.45
NOX 238.58* 105.38
CO 137.46 137.46
VOC 19.02 19.02
Greenhouse Gases
CO2 (mass basis) 22,564.77 22,564.77
CH4 (mass basis) 0.64 0.64
N2O (mass basis) 0.06 0.06
HFCs (mass basis) - -
PFCs (mass basis) - -
SF6 (mass basis) - -
GHGtotal (mass basis) 22,565.47 22,565.47
CO2e (Total) 32,792.00 32,792.00
Hazardous Air
Pollutants (HAP)
Acetaldehyde 0.15 0.15
Acrolein 0.14 0.14
Benzene 0.10 0.10
Ethylbenzene 0.00 0.00
Toluene 0.04 0.04
n-Hexane 0.11 0.11
Xylene 0.01 0.01
Formaldehyde 1.26 1.26
2,2,4-
Trimethylpentane 0.01 0.01
Cyclohexane - -
Total HAP**
1.82 1.82
III. Proposed Synthetic Minor Permit Action
A. 1,061 hp 4SRB Natural Gas-Fired Compressor Engine and Controls
The natural gas industry uses engines to compress natural gas as it is transported via pipelines.
QPC uses a combination of three (3) natural gas-fired, 4SLB compressor engines and one (1)
natural gas-fired, 1,061 hp 4SRB compressor engine. The engine proposed to be permitted under
this permit action is the 1,061 hp 4SRB compressor engine.
Rich-burn engines produce NOx, CO, small amounts of VOC, and very small amounts of
formaldehyde emissions (formaldehyde is the primary hazardous air pollutant (HAP)). The
primary form of emission control for rich-burn engines is non-selective catalytic reduction
(NSCR). NSCR is most effective for reducing NOX and CO emissions. With respect to NOX and
CO, the NSCR enhances the rate of the reduction of NOX to N2, oxidation of CO to CO2, and
oxidation of any remaining hydrocarbons to CO2 and H2O. Because these reactions take place
8
only in low-oxygen, or reducing, atmospheres, the exhaust must contain less than 0.5% O2. This
means that NSCR control systems can function only on stoichiometric or rich-burn engines, and
they require precise control of the air-to-fuel ratio (AFR) in order to maintain satisfactory
catalysis.
We are proposing the use of NSCR with an AFR controller on the 1,061 hp 4SRB engine, which
is capable of reducing uncontrolled NOX emissions to meet the emission limits in the permit at a
maximum operating rate, and NOX pounds per hour (lb/hr) and grams per horsepower-hour
(g/hp-hr) emission limits. The 1,061 hp 4SRB compressor engine must meet NOX emission
limits of 4.68 lb/hr and 2.00 g/hp-hr. We are also proposing emissions control operation and
maintenance restrictions consisting of a limit on the temperature of the engine exhaust entering
the catalyst and a limit on the pressure drop across the catalyst.
We are incorporating the engine requirements from the Part 71 permit and the synthetic minor
permit application into this permit. The following necessary changes to the transferred Part 71
permit requirements should be noted:
1. Modified the requirement to maintain pressure drop across the NSCR system
catalyst bed from within ± 4 inches of water to within ± 2 inches of water. We made
this change for consistency with federal engine standards and other synthetic minor NSR
permits issued by the EPA for sources on Indian country lands.
2. Increased the frequency of monitoring engine exhaust temperature at the inlet to the
catalyst control system from once per hour to continuous. Catalyst operating
efficiency is greatly affected by the temperature of the engine exhaust to be controlled.
As such, the Part 71 permit has the requirement to maintain the optimal temperature
range at all times, but the frequency of monitoring is only once per hour. Thus, to ensure
compliance with the acceptable temperature range in the permit, the monitoring
requirement has been changed from hourly to continuous.
3. Added a series of actions to be taken in the event of a deviation from the required
temperature range of the engine exhaust to the NSCR control system catalyst bed or
in the event of a deviation from the required pressure drop range of the engine
exhaust across the NSCR control system catalyst bed. The actions are to ensure that
there is not a complete failure of the NSCR control system due to plugging, fouling,
destruction, poisoning, etc. The required actions begin with equipment inspections and
end with the possible removal and cleaning of the catalyst or catalyst replacement.
4. Added a maximum 200-hour period for which each overhauled and replaced engine
can operate without the NSCR control system, accompanied by a recordkeeping
provision to track break-in periods. This provision takes into account the time needed
for engine “break-in” before putting it into full-time, continuous operation. Engine
“break-in” can damage the catalyst.
5. Added requirements to monitor CO emissions using a portable analyzer
simultaneously with testing of NOX emissions, to monitor both CO and NOX
emissions simultaneously at least quarterly using a portable analyzer, and to restrict
the adjustment of engines prior to and during emission testing and monitoring. We
are proposing that QPC conduct performance testing and quarterly portable monitoring of
9
CO emissions from the engine at the same time as measuring NOX emissions. While we
understand that the 4SRB engine does not have CO emission limits, we are proposing
additional CO monitoring requirements that were not previously established in the Part
71 permit. We are proposing this additional monitoring using the authority at
40 CFR 49.151(ii)(C).
These provisions have been added to ensure that the NOX emission limits for the 4SRB
engine are being met under normal operating conditions.
In general, there is a fundamental relationship between engine operating parameters and
exhaust emissions. According to standard stoichiometric principles, emission levels of
NOX and CO from natural gas combustion are only independent to a point; thereafter,
they are inversely proportional. Therefore, as NOX emissions in a 4SRB engine are
reduced through AFR and NSCR emission controls, CO emissions will increase after a
certain point. It is feasible for owners and operators of engines to adjust or tune certain
engine operating parameters prior to testing for particular pollutant emissions to assure
compliance with an emission limit. However, if a 4SRB engine equipped with AFR and
NSCR is even slightly below or above the stoichiometric ratios, testing data available to
the EPA has shown that NOX or CO (depending on the direction from stoichiometric
ratio) can increase significantly because the NSCR has difficulty adjusting to non-
stoichiometric conditions. Requiring CO monitoring encourages the operator to test and
monitor a rich burn engine at as close to normal operating conditions as possible and
ensure that operating settings are not adjusted prior to a test such that the CO emission
rates increase to a level that may lead to exceedances of major source emission thresholds
if the engine were operated at those settings for an entire year.
6. Added a requirement to replace the oxygen sensors, used as part of the AFR control
system, within 2,190 hours of engine run-time for the engine. This provision has been
added to ensure optimal performance of the AFR control system.
IV. Air Quality Review
The MNSR regulations at 40 CFR 49.154(d) require that an Air Quality Impact Assessment (AQIA)
modeling analysis be performed if there is reason to be concerned that new construction would cause or
contribute to a National Ambient Air Quality Standard (NAAQS) or PSD increment violation. If an
AQIA reveals that the proposed construction could cause or contribute to a NAAQS or PSD increment
violation, such impacts must be addressed before a pre-construction permit can be issued.
The emissions at this existing facility will not be increasing due to this permit action and the emissions
will continue to be well controlled at all times. In addition, this permit action does not authorize the
construction of any new emission sources, or emission increases from existing units, nor does it
otherwise authorize any other physical modifications to the facility or its operations. In short, this action
will have no adverse air quality impacts; therefore, we have determined that an AQIA modeling analysis
is not required for this action.
V. Tribal Consultations and Communications
We offer tribal government leaders an opportunity to consult on each permit action. We ask the tribal
government leaders to respond to our offer to consult within 30 days of receiving the offer. We invited
10
the Chairperson of the Ute Tribe to consult on this permit action via letter dated July 18, 2016. To date,
the EPA has not received a request for such consultation.
All minor source applications (synthetic minor, minor modification to an existing facility, new true
minor, and general permit) are submitted to both the tribe and the EPA per the application instructions
(see http://www2.epa.gov/region8/tribal-minor-new-source-review-permitting). The tribe has 10
business days from the receipt of the application to communicate to the EPA any preliminary questions
and comments on the application. In the event an AQIA is triggered, we email a copy of that document
to the tribe within 5 business days from the date that we receive it.
Additionally, we notify the tribe of the public comment period for the proposed permit and provide
copies of the application, proposed permit, technical support document, and other supporting
information to be made available for public review, as well as a notice of public comment opportunity to
post in various locations of their choosing on the Reservation. We also notify the tribe of the issuance of
the final permit.
VI. Environmental Justice
On February 11, 1994, the President issued Executive Order 12898, entitled "Federal Actions to Address
Environmental Justice in Minority Populations and Low-Income Populations." The Executive Order
calls on each federal agency to make environmental justice a part of its mission by “identifying and
addressing, as appropriate, disproportionately high and adverse human health or environmental effects
of its programs, policies and activities on minority populations and low-income populations.”
The EPA defines “Environmental Justice” as the fair treatment and meaningful involvement of all
people regardless of race, color, national origin, or income with respect to the development,
implementation, and enforcement of environmental laws, regulations, and polices. The EPA’s goal with
respect to Environmental Justice in permitting is to enable overburdened communities to have full and
meaningful access to the permitting process and to develop permits that address environmental justice
issues to the greatest extent practicable under existing environmental laws. Overburdened is used to
describe the minority, low-income, tribal and indigenous populations or communities in the United
States that potentially experience disproportionate environmental harms and risks as a result of greater
vulnerability to environmental hazards.
This discussion describes our efforts to identify environmental justice communities and assess potential
effects in connection with issuing this permit in Uintah County, Utah, on Indian country lands within the
exterior boundaries of the Uintah and Ouray Indian Reservation.
A. Environmental Impacts to Potentially Overburdened Communities
This permit action does not authorize the construction of any new air emission sources, or air emission
increases from existing units, nor does it otherwise authorize any other physical modifications to the
associated facility or its operations. The air emissions at the existing facility will not increase due to the
associated action and the emissions will continue to be well controlled at all times. We have determined
that issuance of this MNSR permit will not cause or contribute to NAAQS violations, or have adverse
effects on ambient air quality.
11
For purposes of Executive Order 12898 on environmental justice, the EPA has recognized that
compliance with the NAAQS is “emblematic of achieving a level of public health protection that, based
on the level of protection afforded by a primary NAAQS, demonstrates that minority or low-income
populations will not experience disproportionately high and adverse human health or environmental
effects due to the exposure to relevant criteria pollutants.” in re Shell Gulf of Mexico, Inc. & Shell
Offshore, Inc., 15 E.A.D., slip op. at 74 (EAB 2010). This is because the NAAQS are health-based
standards, designed to protect public health with an adequate margin of safety, including sensitive
populations such as children, the elderly, and asthmatics.
Therefore, we conclude that issuance of the aforementioned permit will not have disproportionately high
or adverse human health effects on communities in the vicinity of the Uintah and Ouray Indian
Reservation.
B. Enhanced Public Participation
Given the presence of potentially overburdened communities in the vicinity of the facility, we are
providing an enhanced public participation process for this permit.
1. Interested parties can subscribe to an EPA email list that notifies them of public comment
opportunities on the Indian country lands within the Uintah and Ouray Indian Reservation for
proposed air pollution control permits by visiting https://www.epa.gov/caa-permitting/caa-
permitting-epas-mountains-and-plains-region, and clicking the link to “sign up to be notified by
email of Region 8 CAA permit public comment opportunities.”
2. All minor source applications (synthetic minor, modification to an existing facility, new true
minor or general permit) are submitted to both the tribe and the EPA per the application
instructions (see https://www.epa.gov/caa-permitting/tribal-nsr-permits-region-8).
3. The tribe has 10 business days to communicate to the EPA any preliminary questions and
comments on the application.
4. In the event an AQIA is submitted (voluntarily or at our request), we email a copy of that
document to the tribe within 5 business days from the date we receive it.
5. We notify the tribe of the public comment period for the proposed permit and provide copies of
the notice of public comment opportunity to post in various locations of their choosing on the
Reservation. We also notify the tribe of the issuance of the final permit.
6. We offer the tribal government leaders an opportunity to consult on each proposed permit action.
The tribal government leaders are asked to respond to the EPA’s offer to consult within 30 days
of receiving the letter.
VII. Authority
Requirements under 40 CFR part 49 to obtain a permit apply to new and modified minor stationary
sources, and minor modifications at existing major stationary sources (“major” as defined in
40 CFR 52.21). In addition, the MNSR permitting program provides a mechanism for an otherwise
major stationary source to voluntarily accept restrictions on its potential to emit to become a synthetic
minor source. We are charged with direct implementation of these provisions where there is no approved
12
tribal implementation plan for implementation of the MNSR regulations. Pursuant to Section 301(d)(4)
of the CAA (42 U.S.C. Section 7601(d)), we are authorized to implement the MNSR regulations at
40 CFR part 49 in Indian country. The Fidlar Compressor Station is located on Indian country lands
within the exterior boundaries of the Uintah and Ouray Indian Reservation in Utah. The exact location is
Latitude 40.039722, Longitude -109.456944, in Uintah County, Utah.
VIII. Public Notice
A. Public Comment Period
In accordance with 40 CFR 49.157, we must provide public notice and a 30-day public comment
period to ensure that the affected community and the general public have reasonable access to
the application and proposed permit information. The application, the proposed permit, this
technical support document, and all supporting materials for the proposed permit are available at:
Ute Indian Tribe
Energy and Minerals Department
P.O. Box 70
988 South 7500 East, Annex Building
Fort Duchesne, Utah 84026
Contact: Minnie Grant, Air Coordinator, 435-725-4900 or [email protected]
and
U.S. EPA
Region 8 Air Program Office
1595 Wynkoop Street (8P-AR)
Denver, Colorado 80202-1129
Contact: Colin Schwartz, Environmental Scientist, 303-312-6043 or [email protected]
All documents are available for review at our office Monday through Friday from 8:00 a.m. to
4:00 p.m. (excluding federal holidays). Additionally, the proposed permit and technical support
document can be reviewed on our website at: https://www.epa.gov/caa-permitting/caa-permit-
public-comment-opportunities-region-8.
Any person may submit written comments on the proposed permit and may request a public
hearing during the public comment period. These comments must raise any reasonably
ascertainable issues with supporting arguments by the close of the public comment period
(including any public hearing). Comment may be sent to the EPA address above, or sent via an
email to [email protected], with the topic “Comments on SMNSR Permit for the QPC
Fidlar Compressor Station.”
B. Public Hearing
A request for a public hearing must be in writing and must state the nature of the issues proposed
to be raised at the hearing. We will hold a hearing whenever there is, on the basis of requests, a
significant degree of public interest in a proposed permit. We may also hold a public hearing at
our discretion, whenever, for instance, such a hearing might clarify one or more issues involved
in the permit decision.
13
C. Final Permit Action
In accordance with 40 CFR 49.159, a final permit becomes effective 30 days after permit
issuance, unless: (1) a later effective date is specified in the permit; (2) appeal of the final permit
is made as detailed in the next section; or (3) we may make the permit effective immediately
upon issuance if no comments resulted in a change or denial of the proposed permit. We will
send notice of the final permit action to any individual who commented on the proposed permit
during the public comment period. In addition, the source will be added to a list of final permit
actions which is posted on our website at: https://www.epa.gov/caa-permitting/caa-permits-
issued-epa-region-8. Anyone may request a copy of the final permit at any time by contacting the
Tribal Air Permit Program at (800) 227–8917 or by sending an email to
D. Appeals to the Environmental Appeals Board
In accordance with 40 CFR 49.159, within 30 days after a final permit decision has been issued,
any person who filed comments on the proposed permit or participated in the public hearing may
petition the Environmental Appeals Board (EAB) to review any condition of the permit decision.
The 30-day period within which a person may request review under this section begins when we
have fulfilled the notice requirements for the final permit decision. Motions to reconsider a final
order by the EAB must be filed within 10 days after service of the final order. A petition to the
EAB is under Section 307(b) of the CAA, a prerequisite to seeking judicial review of the final
agency action. For purposes of judicial review, final agency action occurs when we issue or deny
a final permit and agency review procedures are exhausted.
MEMO TO FILE
DATE: August 26, 2016
SUBJECT: Uintah and Ouray Indian Reservation, Fidlar Compressor Station; Questar
Pipeline Company, Environmental Justice
FROM: Colin Schwartz, EPA Region 8 Air Program
TO: Source Files:
205c AirTribal, UO, Questar Pipeline Company- Fidlar CS
SMNSR-UO-000002-2013.001, 9/1/2013
FRED # 105469
On February 11, 1994, the President issued Executive Order 12898, entitled "Federal Actions to
Address Environmental Justice in Minority Populations and Low-Income Populations." The
Executive Order calls on each federal agency to make environmental justice a part of its mission
by “identifying and addressing, as appropriate, disproportionately high and adverse human health
or environmental effects of its programs, policies and activities on minority populations and low-
income populations.”
The EPA defines “Environmental Justice” as the fair treatment and meaningful involvement of
all people regardless of race, color, national origin, or income with respect to the development,
implementation, and enforcement of environmental laws, regulations, and polices. The EPA’s
goal with respect to Environmental Justice in permitting is to enable overburdened communities
to have full and meaningful access to the permitting process and to develop permits that address
environmental justice issues to the greatest extent practicable under existing environmental laws.
Overburdened is used to describe the minority, low-income, tribal and indigenous populations or
communities in the United States that potentially experience disproportionate environmental
harms and risks as a result of greater vulnerability to environmental hazards.
This discussion describes our efforts to identify environmental justice communities and assess
potential effects in connection with issuing this permit in Uintah County, Utah, on Indian country
lands within the Uintah and Ouray Indian Reservation.
Region 8 Air Program Determination
Based on the findings described in the following sections of this memorandum, we conclude that
issuance of the aforementioned permit is not expected to have disproportionately high or adverse
human health effects on overburdened communities in the vicinity of the facility.
Permit Request
The EPA received an application from Questar Pipeline Company (QPC) requesting a synthetic
minor MNSR permit for the Fidlar Compressor Station on November 1, 2013.
The application contained a request to transfer the limits on the 1,061 hp 4SRB compressor
engine that were established in the Part 71 permit issued on July 15, 2011. This proposed permit
reflects the incorporation of NOX emission limits on the engine. These proposed limits, if made
legally and practically enforceable, would allow QPC to use the controlled NOX emission rates in
determining potential to emit and applicability of other CAA requirements, such as the
Prevention of Significant Deterioration (PSD), MNSR and Part 71 Permit Programs.
Upon compliance with this permit, QPC will have maintained legally and practically enforceable
requirements to reduce emissions that can be accounted for when determining the applicability of
other CAA requirements, such as permitting requirements under the PSD Permit Program and
the Part 71 Permit Program.
The facility is located at:
SW1/4, NW1/4 Sec 16 T9S R22E
Latitude 40.039722, Longitude -109.456944
Air Quality Review
The MNSR regulations at 40 CFR 49.154(d) require that an Air Quality Impact Assessment
(AQIA) modeling analysis be performed if there is reason to be concerned that new construction
would cause or contribute to a National Ambient Air Quality Standard (NAAQS) or PSD
increment violation. If an AQIA reveals that the proposed construction could cause or contribute
to a NAAQS or PSD increment violation, such impacts must be addressed before a pre-
construction permit can be issued.
The emissions at this existing facility will not be increasing due to this permit action and the
emissions will continue to be well controlled at all times. In addition, this permit action does not
authorize the construction of any new emission sources, or emission increases from existing
units, nor does it otherwise authorize any other physical modifications to the facility or its
operations. In short, this action will have no adverse air quality impacts; therefore, we have
determined that an AQIA modeling analysis is not required for this action.
Environmental Impacts to Potentially Overburdened Communities
This permit action does not authorize the construction of any new air emission sources, or air
emission increases from existing units, nor does it otherwise authorize any other physical
modifications to the associated facility or its operations. The air emissions at the existing facility
will not increase due to the associated action and the emissions will continue to be well
controlled at all times. We have determined that issuance of this MNSR permit will not cause or
contribute to NAAQS violations, or have adverse effects on ambient air quality.
For purposes of Executive Order 12898 on environmental justice, the EPA has recognized that
compliance with the NAAQS is “emblematic of achieving a level of public health protection
that, based on the level of protection afforded by a primary NAAQS, demonstrates that minority
or low-income populations will not experience disproportionately high and adverse human health
or environmental effects due to the exposure to relevant criteria pollutants.” in re Shell Gulf of
Mexico, Inc. & Shell Offshore, Inc., 15 E.A.D., slip op. at 74 (EAB 2010). This is because the
NAAQS are health-based standards, designed to protect public health with an adequate margin of
safety, including sensitive populations such as children, the elderly, and asthmatics.
Therefore, we conclude that issuance of the aforementioned permit will not have
disproportionately high or adverse human health effects on communities in the vicinity of the
Uintah and Ouray Indian Reservation.
Tribal Consultation and Enhanced Public Participation
Given the presence of potentially overburdened communities in the vicinity of the facility, we
are providing an enhanced public participation process for this permit.
1. Interested parties can subscribe to an EPA email list that notifies them of public comment
opportunities on the Indian country lands within the Uintah and Ouray Indian Reservation
for proposed air pollution control permits by visiting https://www.epa.gov/caa-
permitting/caa-permitting-epas-mountains-and-plains-region, and clicking the link to
“sign up to be notified by email of Region 8 CAA permit public comment opportunities.”
2. All minor source applications (synthetic minor, modification to an existing facility, new
true minor or general permit) are submitted to both the tribe and the EPA per the
application instructions (see https://www.epa.gov/caa-permitting/tribal-nsr-permits-
region-8).
3. The tribe has 10 business days to communicate to the EPA any preliminary questions and
comments on the application.
4. In the event an AQIA is submitted (voluntarily or at our request), we email a copy of that
document to the tribe within 5 business days from the date we receive it.
5. We notify the tribe of the public comment period for the proposed permit and provide
copies of the notice of public comment opportunity to post in various locations of their
choosing on the Reservation. We also notify the tribe of the issuance of the final permit.
6. We offer the tribal government leaders an opportunity to consult on each proposed permit
action. The tribal government leaders are asked to respond to the EPA’s offer to consult
within 30 days of receiving the letter.
Page 1 of 2
MEMO TO FILE
DATE: August 26, 2016
SUBJECT: Uintah and Ouray Indian Reservation, Fidlar Compressor Station; Questar Pipeline
Company, Environmental Justice
FROM: Colin Schwartz, EPA Region 8 Air Program
TO: Source Files:
205c AirTribal, UO, Questar Pipeline Company- Fidlar CS
SMNSR-UO-000002-2013.001, 9/1/2013
FRED # 105469
Pursuant to Section 7 of the Endangered Species Act (ESA), 16 U.S.C. §1536, and its implementing
regulations at 50 CFR, part 402, the EPA is required to ensure that any action authorized, funded, or
carried out by the Agency is not likely to jeopardize the continued existence of any Federally-listed
endangered or threatened species or result in the destruction or adverse modification of such species’
designated critical habitat. Under ESA, those agencies that authorize, fund, or carry out the federal
action are commonly known as “action agencies.” If an action agency determines that its federal action
“may affect” listed species or critical habitat, it must consult with the U.S. Fish and Wildlife Service
(FWS). If an action agency determines that the federal action will have no effect on listed species or
critical habitat, the agency will make a “no effect” determination. In that case, the action agency does
not initiate consultation with the FWS and its obligations under Section 7 are complete.
In complying with its duty under ESA, the EPA, as the action agency, examined the potential effects on
listed species and designated critical habitat relating to issuing this Clean Air Act (CAA) synthetic
minor New Source Review permit in Uintah County, Utah, on Indian country lands within the Uintah
and Ouray Indian Reservation.
Region 8 Air Program Determination
The EPA has concluded that the proposed synthetic minor NSR permit actions will have “No effect” on
listed species or critical habitat. This proposed permit action does not authorize the construction of any
new air emission sources, or air emission increases from existing units, nor does it otherwise authorize
any other physical modifications to the associated facility or its operations. Because the EPA has
determined that the federal action will have no effect, the agency made a “No effect” determination, did
not initiate consultation with the FWS and its obligations under Section 7 are complete.
Permit Request
The EPA received an application from Questar Pipeline Company (QPC) requesting a synthetic minor
MNSR permit for the Fidlar Compressor Station on November 1, 2013.
The application contained a request to transfer the limits on the 1,061 hp 4SRB compressor engine that
were established in the Part 71 permit issued on July 15, 2011. This proposed permit reflects the
Page 2 of 2
incorporation of NOX emission limits on the engine. These proposed limits, if made legally and
practically enforceable, would allow QPC to use the controlled NOX emission rates in determining
potential to emit and applicability of other CAA requirements, such as the Prevention of Significant
Deterioration (PSD), MNSR and Part 71 Permit Programs.
Upon compliance with this permit, QPC will have maintained legally and practically enforceable
requirements to reduce emissions that can be accounted for when determining the applicability of other
CAA requirements, such as permitting requirements under the PSD Permit Program and the Part 71
Permit Program.
The facility is located at:
SW1/4, NW1/4 Sec 16 T9S R22E
Latitude 40.039722, Longitude -109.456944
Conclusion
The EPA has concluded that the proposed synthetic minor NSR permit action will have “No effect” on
listed species or critical habitat. This proposed permit action does not authorize the construction of any
new air emission sources, or air emission increases from existing units, nor does it otherwise authorize
any other physical modifications to the associated facility or its operations. The emissions, approved at
present, from each existing facility will not increase due to the associated permit action. Because the
EPA has determined that the federal action will have no effect, the agency will make a “No effect”
determination. In that case, the EPA does not initiate consultation with the FWS and its obligations
under Section 7 are complete.
Page 1 of 2
MEMO TO FILE
DATE: August 26, 2016
SUBJECT: Uintah and Ouray Indian Reservation, Fidlar Compressor Station; Questar Pipeline
Company, Environmental Justice
FROM: Colin Schwartz, EPA Region 8 Air Program
TO: Source Files:
205c AirTribal, UO, Questar Pipeline Company- Fidlar CS
SMNSR-UO-000002-2013.001, 9/1/2013
FRED # 105469
Section 106 of the National Historic Preservation Act (NHPA) requires federal agencies to take into
account the effects of their undertakings on historic properties and afford the Advisory Council on
Historic Preservation (ACHP) a reasonable opportunity to comment with regard to such undertakings.
Under the ACHP’s implementing regulations at 36 C.F.R. Part 800, Section 106 consultation is
generally with state and tribal historic preservation officials in the first instance, with opportunities for
the ACHP to become directly involved in certain cases. An “undertaking” is “a project, activity, or
program funded in whole or in part under the direct or indirect jurisdiction of a Federal agency,
including those carried out by or on behalf of a Federal agency; those carried out with Federal financial
assistance; and those requiring a Federal permit, license or approval.” 36 C.F.R. § 800.16(y).
Under the NHPA Section 106 implementing regulations, if an undertaking is a type of activity that has
the potential to cause effects on historic properties, assuming any are present, then federal agencies
consult with relevant historic preservation partners to determine the area of potential effect (APE) of the
undertaking, to identify historic properties that may exist in that area, and to assess and address any
adverse effects that may be caused on historic properties by the undertaking. If an undertaking is a type
of activity that does not have the potential to cause effects on historic properties, the federal agency has
no further obligations. 36 C.F.R. § 800.3(a)(1).
This memorandum describes EPA’s efforts to assess potential effects on historic properties in
connection with to issuing this Clean Air Act (CAA) synthetic minor New Source Review permit in
Uintah County, Utah, on Indian country lands within the Uintah and Ouray Indian Reservation. As
explained further below, EPA is finding that the proposed action does not have the potential to cause
effects on historic properties, even assuming such historic properties are present.
Permit Request
The EPA received an application from Questar Pipeline Company (QPC) requesting a synthetic minor
MNSR permit for the Fidlar Compressor Station on November 1, 2013.
The application contained a request to transfer the limits on the 1,061 hp 4SRB compressor engine that
were established in the Part 71 permit issued on July 15, 2011. This proposed permit reflects the
Page 2 of 2
incorporation of NOX emission limits on the engine. These proposed limits, if made legally and
practically enforceable, would allow QPC to use the controlled NOX emission rates in determining
potential to emit and applicability of other CAA requirements, such as the Prevention of Significant
Deterioration (PSD), MNSR and Part 71 Permit Programs.
Upon compliance with this permit, QPC will have maintained legally and practically enforceable
requirements to reduce emissions that can be accounted for when determining the applicability of other
CAA requirements, such as permitting requirements under the PSD Permit Program and the Part 71
Permit Program.
The facility is located at:
SW1/4, NW1/4 Sec 16 T9S R22E
Latitude 40.039722, Longitude -109.456944
Finding of No Potential to Cause Effects
The EPA has reviewed the proposed actions for potential impacts on historic properties. Because the
activities authorized by the EPA permits does not authorize the construction of any new air emission
sources, or air emission increases from existing units, nor does it otherwise authorize any other physical
modifications to the facility or its operations, the Agency finds that this project does not have the
potential to cause effects on historic properties, even assuming any are present.
State and Tribal Consultation
Because this undertaking is a type of activity that does not have the potential to cause effects on historic
properties, the EPA has no further obligations under Section 106 of the National Historic Preservation
Act or 36 C.F.R. part 800.
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION 8
1595 Wynkoop Street Denver, CO 80202-1129
Phone 800-227-8917 http://www.epa.gov/aboutepa/epa-region-8-mountains-and-plains
Ref: 8P-AR
CERTIFIED MAIL RETURN RECEIPT REQUESTED
Honorable Shaun Chapoose, Chairman Ute Indian Tribe P.O. Box 70 Fort Duchesne, Utah 84026
JUL 18 ZOI
Re: Notification of Consultation and Coordination with Respect to the Issuance of Air Pollution Control Permit Pursuant to the Tribal Minor New Source Review (MNSR) Permit Program for an Existing Natural Gas Compressor Station on the Uintah and Ouray Indian Reservation
Dear Chairman Chapoose:
The U.S. Environmental Protection Agency Region 8 is initiating consultation and coordination with the Ute Indian Tribe with respect to issuance of a Clean Air Act air pollution control MNSR permit for an existing natural gas compressor station on Indian country lands within the Uintah and Ouray Indian Reservation in Uintah County, Utah. In accordance with the MNSR Permit Program at 40 CPR Part 49, owner and operator Questar Pipeline Company (QPC), is requesting a MNSR permit with federally enforceable air pollutant emission limits for the existing Fidlar Compressor Station.
The Fidlar Compressor Station receives natural gas from and delivers it to any one of QPC's main lines that transport natural gas east, west and north to existing markets and interconnecting points with other interstate pipelines. QPC submitted a synthetic minor MNSR permit application to recognize the installation and operation of a non-selective catalytic reduction system on an existing rich-bum natural gas-fired compressor engine operating at the facility to control emissions. Synthetic minor emission limits were previously established for this engine in the operating permit (Permit# V-U0-0002-05.01, July 15, 2011) for the Fidlar Compressor Station issued pursuant to the Title V Operating Permit Program at 40 CPR Part 71 as a gap-filling measure until final promulgation of the MNSR Permit Program.
This consultation and coordination process is being conducted based on the EPA Policy on Consultation and Coordination with Indian Tribes (www.epa.gov/tribal/consultation/consult-policy.htm). The EPA invites you and your designated consultation representative(s) to participate in this process. In an effort to provide timely information to the Tribe, the EPA would like to schedule consultation and coordination within 30 days after you receive this letter.
In addition to offering government-to-government consultation, the EPA plans to regularly coordinate and communicate with the Ute Tribe's Acting Energy, Minerals and Air Director, Bruce Pargeets, for facilities located on Indian country lands within the Uintah and Ouray Indian Reservation. If you would prefer to designate an alternative representative for communication on air pollution control permitting
matters, please notify us of that person's name and contact information. We will keep the tribal government informed and will seek your input on these permits.
The EPA welcomes the opportunity to consult and coordinate with the Tribe. If you choose to consult about this permitting action, we will work with your tribal government to develop a consultation plan including a description of the process we would follow, opportunity for your input, and timeline for us to provide feedback and to complete the consultation. We will send a draft consultation plan for your review as soon as practical after we receive your reply to this letter. The agency's goal will be to ensure that you have an opportunity to provide tribal input into this permit action.
We request that you reply in writing to this letter within the next 30 days if the Tribe desires to consult on this permit action. The official EPA contact person for this consultation and coordination process is Claudia Smith, a permit engineer on my staff.
Thank you very much for your attention to this matter. Please contact me at (303) 312-6392 or your staff can contact Claudia Smith at (303) 312-6520 or [email protected] should you have any questions on this action. We look forward to hearing from you on this important matter.
Sincerely,
Darcy O'Connor Acting Assistant Regional Administrator Office of Partnerships and Regulatory Assistance
cc: Edred Secakuku, Vice Chairman, Uintah and Ouray Business Committee Tony Small, Councilman, Uintah and Ouray Business Committee Ronald Wopsock, Councilman, Uintah and Ouray Business Committee Justin Cummings V anberhoop, Councilman, Uintah and Ouray Business Committee Bruce Ignacio, Councilman, Uintah and Ouray Business Committee Reannin Tapoof, Executive Assistant, Uintah and Ouray Business Committee Tom Fredericks, Esq., Fredericks Peebles & Morgan LLP Bruce Pargeets, Acting Director, Energy, Minerals and Air, Ute Indian Tribe Minnie Grant, Air Coordinator, Energy, Minerals, and Air, Ute Indian Tribe
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QUEST~R
October 30, 2013
U.S. EPA, Region VIII Attn: Federal Minor NSR Permit Coordinator Air & Radiation Program (8P-AR) 1595 Wynkoop Street Denver, CO 80202-1129
Re: Tribal Minor New Source Review Permit Application
Dear Sir or Madam:
Questar Pipeline Company
1140 West 200 South
P. 0. Box 45360
Salt Lake City, UT 84145-0360
Tel 801 324 5555
Please find attached an application for a synthetic minor permit for equipment located in Indian Country. Questar Pipeline Company (QPC) is requesting enforceable limits for NOx on an existing reciprocating engine (Unit FS02) at the Fidlar Compressor Station on the Uintah and Ouray Indian Reservation in Utah. Fidlar currently operates under Part 71 Permit number V-U0-0002-05.01.
QPC has prepared an application consisting of Form NEW, Form SYNMIN, and supporting documentation. In addition, a signed form CT AC is enclosed since the existing unit opei;ates at a Part 71 source.
Questions or requests for additional information should be directed to me at (801) 324-3820 or via electronic mail: [email protected].
Sincerely,
~·~ Scott R. Bassett Sr. Environmental Coordinator
Attachments
cc: Ute Tribe Environmental Contact
Questar Pipeline Company Fidlar Compressor Station Part 71 Permit #V-U0-0002-05.01
Application for Tribal Minor New Source Review-Existing Unit FS02
Narrative Description
Unit FS02 is a natural gas transmission compressor driven by a spark ignition, four-stroke, rich burn, reciprocating internal combustion engine (RICE). The engine is equipped with nonselective catalytic reduction (NSCR) pollution control equipment and an air-fuel ratio combustion control system. Unit FS02 is one of four compressor units at the Fidlar Compressor Station. Fidlar Compressor Station is a natural gas transmission compressor station situated on four interconnecting, interstate pipelines owned and operated by the applicant. Fidlar Station is capable of boosting pipeline pressure on the four transmission pipelines flowing north, east, and west.
Operating Schedule
Unit FS02 is proposed to operate a full 8760 hours per year.
Fuel Information
Unit FS02 uses pipeline quality natural gas as the sole source of fuel.
Process Flow Information
Unit FS02 is capable compressing natural gas by drawing gas from the Fidlar Station suction piping header, mechanically compressing the gas in a piston, and discharging the gas to the discharge piping header. Since the gas heats up during compression, the gas may flow through a discharge gas cooler before flowing back into a transmission pipeline. The discharge gas cooler is a simple process whereby fans circulate ambient air across fins containing the pressurized gas. Heat from the process is radiated to atmosphere. There is no contact between the gas and the air, the pressurized gas simply flows through the cooler before being discharged to the transmission pipeline. A fuel gas system routes gas from the natural gas pipeline to the engine for combustion. Mechanical work created in the engine drives the compressor pistons.
Proposed Emission Units
Existing Unit FS02- Reciprocating Compressor Engine Manufacturer: White Superior Model: 120-825 Serial Number: 299499 Fuel: Pipeline Quality Natural Gas Combustion: Four-stroke, Rich Burn Horsepower: 1061
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Equivalent Heat Rate: 10.79 MMBtu/Hour Installation Date: 12/3/1983 Pollution Controls: NSCR and AFRC Controls Installed: 1995 Part 71 Enforceable Limit Effective Date: July 25, 2011 Regulatory Status: Engine was not constructed, reconstructed, or modified after June 12, 2006 and is not subject to 40 CFR Part 60 Subpart JJJJ. Engine is subject to the area source requirements of 40 CFR 63 Subpart ZZZZ.
Criteria Pollutant Emission Estimates
Please see form NEW emission table E(ii) and the emission calculation spreadsheet attached to Form SYNMIN for reciprocating Unit FS02.
Air Quality Review
The unit is an existing unit that has been in operation at the subject location since 1983. The unit has complied with the enforceable limits being requested since 2011. It reasons that the pollution control equipment can only help to improve local air quality. The Uintah Basin is currently a study area for ground level ozone. Upgrading control equipment and adding enforceable limits to existing equipment are likely solutions to some of the issues facing the region. In this regard, it would appear that the source is ahead of the curve.
Endangered Species Act
Since the subject equipment has been in existence since 1983 and the compressor station itself in operation since 1969, it doesn't appear the proposed action (enforceable limit on existing equipment) would likely affect any listed species in the area.
National Historic Preservation Act
Since the proposed action doesn't involve construction of new facilities, it is not likely to affect any cultural resources in the area (i.e., the proposed action is limiting emissions from an existing source located in an existing fenced facility. No ground disturbance is proposed) .
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY FEDERAL MINOR NEW SOURCE REVIEW PROGRAM IN INDIAN COUNTRY
40 CFR 49.151
Application For Synthetic Minor Limit (Form SYNMIN)
Use of this information request form is voluntary and not yet approved by the Office of Management and Budget. The following is a check list of the type of information that Region 8 will use to process information on your proposed project. While submittal of this form is not required, it does offer details on the information we will use to complete your requested approval and providing the information requested may help expedite the process. Use of application forms for this program is currently under Office of Management and Budget review and these information request forms will be replaced/updated after that review is com leted.
Please submit information to following two entities:
Federal Minor NSR Permit Coordinator U.S. EPA, Region 8 1595 Wynkoop Street, 8P-AR Denver, CO 80202-1129 [email protected]
For more information, visit: http://www2.epa.gov/region8/tribal-minor-newsource-review-permitting
A. GENERAL INFORMATION Company Name Questar Pipeline Company
Company Contact or Owner Name Scott Bassett Mailing Address
The Tribal Environmental Contact for the specific reservation:
If you need assistance in identifying the appropriate Tribal Environmental Contact and address, please contact:
Source Name Fidlar Compressor Station - Unit FS02
j Title Sr. Env. Coordinator
Mailstop: DNR 206, P.O. Box 45360, Salt Lake City, UT 84145-0360 Email Address scott.bassett@q uestar .com Telephone Number Facsimile Number (801) 324-3820 (801) 324-3883
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B. ATTACHMENTS For each criteria air pollutant, hazardous air pollutant and for all emission units and air pollutant-generating activities to be covered by a limitation, include the following:
g'Jtem 1 - The proposed limitation and a description of its effect on current actual, allowable and the potential to emit. Q""Item 2 - The proposed testing, monitoring, recordkeeping, and reporting requirements to be used to demonstrate and assure compliance with the proposed limitation. 0" Item 3 - A description of estimated efficiency of air pollution control equipment under present or anticipated operating conditions, including documentation of the manufacturer specifications and guarantees. Q"'J:tem 4- Estimates of the Post-Change Allowable Emissions that would result from compliance with the proposed limitation, including all calculations for the estimates. '1'Item 5- Estimates of the potential emissions of Greenhouse Gas (GHG) pollutants:
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Questar Pipeline Company Fidlar Compressor Station Part 71 Permit #V-U0-0002-05.01
Application for Tribal Minor New Source Review-Existing Unit FS02
Form SYNMIN Part B Narrative and Attachments:
Item 1 - The proposed limitation and a description of its effect on current actual, allowable, and the potential-to-emit.
The applicant is proposing to limit emissions of NOx from an existing RICE unit at a Part 71 source located on the Uinta and Ouray Indian Reservation in eastern Utah. The proposed NOx limit is already enforceable under the existing Part 71 permit as a "stop gap" measure adopted during development of the Indian Country permitting rules. The applicant intends to obtain an underlying synthetic minor permit to support this limit in the Part 71 permit that is currently under review for renewal.
Specifically, the applicant intends to make NOx emission reductions from existing NSCR equipment enforceable. Historically, an uncontrolled NOx emission rate of 35.09 lb/hr (153.69 tons/year) was used in calculating potential-to-emit from unit FS02. The applicant is requesting an enforceable limit of 4.68 lb/hr (20.50 tons/year) NOx.
The proposed limitation will not affect current actual, allowable, or PTE since the Part 71 limit has been enforceable since 2011. Periodic testing and monitoring requirements (discussed below) have demonstrated compliance with the proposed enforceable limit.
Item 2 - The proposed testing, monitoring, recordkeeping, and reporting requirements to be used to demonstrate and ensure compliance with the proposed limitation.
The applicant is proposing the same monitoring, recordkeeping, and reporting requirements that are currently stated in Part 71 permit V-U0-0002-05.01 Section V. Requested Emission Limits - Engine FS02 (see attached permit excerpt).
Item 3 -A description of the estimated efficiency of air pollution control equipment under present or anticipated operating conditions, including documentation of the manufacturer specifications and guarantees.
Historic PTE numbers from the initial Part 71 permit application for Fidlar Station assign an uncontrolled NOx emission rate of 15.0 grams/horsepower-hour (35.09 lb/hr) for unit FS02. Based on the maximum uncontrolled PTE of 35.09 lb/hr, the proposed limit of 4.68 lb/hr represents a NOx control efficiency of at least 87%. Because the original NSCR catalyst element was installed in 1995, the applicant does not have documentation of expected pollution control efficiency. A replacement element was ordered and installed in 2010 (see attached purchase order); however, we were unable to obtain a specification sheet since the replacement was simply warehouse stock and not a new element from a
specialized vendor. Annual performance testing of the engine with the replacement catalyst has demonstrated NOx control effectiveness in excess of 87% (see attached test summary sheets from 2011, 2012, and 2013).
Item 4- Estimates of the Post-Change Allowable Emissions that would result from compliance with proposed limitation, including all calculations of the estimates.
The proposed limitation is to limit Unit FS02 to 2.0 grams/horsepower-hour and 4.68 pounds/hour NOx emissions. The resulting annual allowable emissions are 20.49 tons/year NOx, compared with an historic worst case uncontrolled potential-to-emit of 153.69 tons/year. Please see attached calculations prepared previously for the Part 71 permit modification that show the proposed allowable emissions for all pollutants from Unit FS02. Emissions from unit FS07 (standby generator) have not been removed from the calculation spreadsheet and are for information purposes only as this application only addresses unit FS02.
Item 5 - Estimates of the potential emissions of Greenhouse Gas (GHG) pollutants.
Greenhouse gas emissions from combustion have been calculated for all major equipment at Fidlar Compressor Station and total 32,792 tons/year of CO2 equivalent (including CO2, CH4, and N20). Specifically, Unit FS02 has a GHG potential-to-emit of 5,016 tons/year C02e. As such, neither Unit FS02 nor Fidlar Station is subject to PSD review (see attached calculations). Please note: Unit FS02 is not a source of HFC's, PFC's, or SF6•
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ITEM2 ATTACHMENT
PART 71 PERMIT EXCERPT
V. Requested Emission Limits - Engine FS02
V.A. Applicability
The following requirements have been created, at the permittee's request, to recognize the non-selective catalytic reduction (NSCR) controls on engine FS02, a 1,061 hp, natural gas fired, White Superior 12G-825 compression engine; serial number 299499. The requirements are intended to establish enforceable restrictions on the PTE of NOx from engine FS02.
V.B. Emission Limits
Emissions from engine FS02 equipped with NSCR catalyst shall not exceed:
1. 2.0 grams per horse power-hour (g/hp-hr) of NOx emissions; and
2. 4.68 pounds per hour (lbs/hr) of NOx emissions.
V.C. Work Practice and Operational Requirements
1. Engine FS02 shall be equipped with an AFR and NSCR system for the control of NOx.
2. The permittee shall follow, for engine FS02 and associated AFR and NSCR systems, the manufacturer's recommended maintenance schedule and procedures to ensure optimum performance of the unit and control system.
3. The permittee shall install a temperature-sensing device before the NSCR system on engine FS02 in order to monitor the inlet temperature to the NSCR. The temperature-sensing device shall be accurate to within 0.75% of span.
4. The inlet temperature to the NSCR system shall be maintained at all times engine FS02 operates in accordance with manufacturer's specifications.
5. The inlet temperature to the NSCR system shall be measured at least hourly during the operation of engine FS02.
6. If the inlet temperature to the NSCR system deviates from the acceptable range according to manufacturer specifications, then the following actions shall be taken:
(a) Immediately upon determining a deviation of the NSCR inlet temperature, the cause will be investigated. Investigation may include monitoring of NOx emissions to ensure the NSCR system is functioning and testing the temperature sensing device. If the cause is determined to be the NSCR system, then the catalyst shall be inspected and cleaned or replaced, if necessary.
(b) If the problem can be corrected by following the engine and/or the NSCR manufacturer's recommended procedures, then the permittee shall correct the problem within 24 hours of inspecting the engine and NSCR.
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( c) If the problem can not be corrected using the manufacturer's recommended procedures, then the engine shall not be returned to operation until the NSCR inlet temperature is measured and found to be within the acceptable temperature range for the engine. The permittee shall also notify EPA in writing of the problem within 10 working days of observing the problem and include in the notification the cause of the problem and a corrective action plan that outlines the steps and timeframe for bringing the NSCR inlet temperature range into compliance. (The corrective action may include removal and cleaning of the catalyst according to the manufacturer's methods or replacement of the catalyst.)
7. A baseline pressure drop across the NSCR system shall be established during the initial performance test. A new baseline pressure drop across the NSCR system shall be established each time the catalyst is cleaned or replaced.
8. The pressure drop across an NSCR system shall be measured at least hourly during the operation of the engine.
9. During operation the pressure drop across the NSCR system shall be maintained to within four ( 4) inches of water from the baseline pressure drop reading taken during the most recent performance test.
10. If the pressure drop exceeds four ( 4) inches of water from the baseline pressure drop reading taken during the most recent performance test, the cause will be investigated. Investigation may include monitoring of NOx emissions to ensure the NSCR system is functioning and testing the pressure transducers. If the cause is determined to be the NSCR system, then the catalyst shall be inspected and cleaned or replaced, if necessary.
11. The permittee' s completion of any or all of the actions prescribed by this permit shall not constitute, nor qualify as, an exemption from the NOx emission limit in this permit.
12. Engine FS02 shall be fired only with natural gas. The natural gas shall be pipeline-quality in all respects except that the CO2 concentration in the gas shall not be required to be within pipeline-quality.
[Note to Permittee: The purpose of permit condition 12, above, is to ensure that there are no contaminants in the fuel that might foul the catalyst. in general, pipeline-quality natural gas is ( 1) within ± 5% of the heating value of pure methane, or 1,010 Btu/per cubic foot under standard atmospheric conditions, and (2) free of water and toxic or corrosive contaminants. However, CO2 is not a potentialfoulant of the catalyst and has therefore been excluded from the requirement.]
V.D. Testing Requirements
1. An initial performance test shall be conducted for engine FS02 for measuring NOx emissions to demonstrate compliance with the emission limits in this section. The initial performance test for NOx shall be conducted within forty-five (45) calendar days of the effective date of this permit.
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2. Upon change out of engine FS02, a performance test shall be conducted for measuring NOx emissions from the unit to demonstrate compliance with the emission limits in V.B. The performance test for NOx for each unit shall be conducted within forty-five (45) calendar days of initial startup of the replacement engine.
3. Upon the cleaning or replacement of the NSCR catalyst, a performance test shall be conducted for measuring NOx emissions from the unit to demonstrate compliance with the emission limits and to establish a new baseline pressure drop. The performance test shall be conducted within forty-five (45) calendar days of startup of the engine with the new catalyst.
4. The performance test for NOx emissions shall be conducted in accordance with the appropriate test methods specified in 40 CFR part 60, Appendix A. The permittee may submit to EPA a written request for approval of an alternate testing method, but shall only use that alternate test method after obtaining written approval from EPA.
5. The inlet temperature to the NSCR system and the pressure drop across the NSCR system shall both be measured during the performance test for measuring NOx emissions.
6. All tests for NOx emissions for engine FS02 must meet the following requirements:
(a) All tests shall be performed at a maximum operating rate (90% to 110% of engine design capacity).
(b) During each test run, data shall be collected on all parameters necessary to document how NOx emissions were measured or calculated (such as test run length, minimum sample volume, volumetric flow rate, moisture and oxygen corrections, etc.).
(c) Each test shall consist of at least three (3) 1-hour or longer valid test runs. Emission results shall be reported as the arithmetic average of all valid test runs and shall be in terms of g/hp-hr and lbs/hr.
(d) A source test plan for NOx emissions shall be submitted to EPA for approval within thirty (30) calendar days of the effective date of this permit. The source test plan shall include and address the following elements:
(i) Purpose of the test; (ii) Unit and NSCR system to be tested; (iii) Expected engine operating rate during test; (iv) Schedule/dates for the test; (v) Sampling and analysis procedures (sampling locations, test methods,
laboratory identification); (vi) Quality assurance plan (calibration procedures and frequency, sample
recovery and field documentation, chain of custody procedures); and (vii) Data processing and reporting (description of data handling and quality
control procedures, report content).
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V.E. Monitoring Requirements
1. The permittee shall conduct annual performance tests for engine FS02 for measuring NOx emissions to demonstrate compliance with the emission limit. The performance tests for NOx shall be conducted in accordance with the test methods specified in 40 CFR Part 60, Appendix A. The permittee may submit to EPA a written request for approval of an alternate testing method, but shall only use that alternate test method after obtaining written approval from EPA.
2. The permittee shall measure NOx emissions from engine FS02 quarterly to demonstrate compliance with the NOx emission limit.
3. The permittee shall measure the quarterly NOx emissions using a portable analyzer and a monitoring protocol approved by EPA. Monitoring for NOx emissions from engine FS02 shall commence during the first complete calendar quarter following the permittee's submittal of the initial performance test results for NOx to EPA. The annual performance test required in this section, shall meet the monitoring requirement for that quarter.
V.F. Recordkeeping Requirements
The permittee shall comply with the following recordkeeping requirements:
1. Record shall be kept of the results of all NOx performance tests and monitoring required in this permit.
2. Records shall be kept of all temperature measurements requirements of this permit, as well as a description of any corrective actions taken pursuant to this section.
3. Records shall be kept of all pressure drop measurements required by this permit, as well as a description of any corrective actions taken.
4. Records shall be kept of vendor specifications to demonstrate that the accuracy of the temperature-sensing devices on the NSCR system is at least as accurate as that required in this permit.
5. Records shall be kept of vendor specifications to demonstrate that the accuracy of the pressure-sensing devices on the NSCR system is at least as accurate as that required in this permit.
V.G. Reporting Requirements
1. The permittee shall submit to EPA a written report of the results of the NOx performance tests and temperature and pressure drop measurements required in this permit. This report shall be submitted within 60 (sixty) calendar days of the date of testing completion.
2. The permittee shall submit to EPA, as part of the semi-annual monitoring reports, a report of any instances where the NSCR system inlet temperature deviates from the acceptable range
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and where the pressure drop across the NSCR system deviates from the acceptable reading, as well as a description of any corrective actions. If no such instances have been detected, then a statement shall be provided to say so.
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ITEM 3 ATTACHMENTS
CATALYST ELEMENT PURCHASE ORDER
& PERFORMANCE TEST RESULTS
QUSST~R PURCHASE REQUISITION POR
COMPANY: NO. 12082729
D QC D QES D QGC D QSTP @ QPC D QOPC D QTSC D OTHER'-----
DEPAATMENT REQUSITIONOATE
Vernal Operation 03/12/10 DATE REQUIRED (THE AClVAL DATE OROER 1$ NEEOEO) SHIP TO
04/12/10 QPC TO Be USEO F<JO 1601 E 1700 S Fidlar #2 Convertor Vernal, Utah 84078
ALL MATERIALS AND SERVICES MUST BE REQUISITIONED THROUGH THE PURCHASING DEPARTMENT EXCEPT IN CASES COVERED BY A PROCUREMENT CARD. CONTACT THE PURCHASING DEPARTMENT FOR PRICING AND FREIGHT INFORMATION.
LINE NO. QUANTITY DESCRIPTION
1 1 Replacement Element for PowerHouse Catalytic Convertor
MIN: 3WC53112 S/N: 260330 MFG Date 9-95
Waukesha-Peaece Industries
713-723-1050
Maintenance Fidlar Station
0 CAPITAL BUDGET Ill OPERATING BUDGET Complete appropriate categories:
ACCOUNT DEPT ID TRANSACTION OPERATING UNIT PRODUCT PROJECT ACTIVITY
PURCHASING USE ONI. Y APPROVAL SIGNATURES: (Rererio Signatory ~pro .... ~es)
l'l.RCINE ORDER DATE ISSUED RECUESTOR (PRINT NM£) PHCNE EJCT. ·11~ DATE
Neil Wilcken 4057 03112/10
VENDOR......e AnENTION APPRa,AL tpRJNT NAME) PHONEEXI'. S>GHJft1J' \J ,•, DATE
l '·· t-,Cf),, ADCRfSS Pt<ON!a APPRa,AJ.. (FRINT NAME) PHONE EXI'. SIGNAME
. : \.,./ DATE
FAX APPf!OIN.. (FRINT NAME) PHONE EJCT. SIGNAlVRI: DATE
50090 04/08
Table 2: Summary of Results, Runs 1-3 (Unit FS02, Test Summary)
Operational Data, Concentrations, Exhaust Flow Rates,
Mass Emission Rates
Client: Questar Pipeline Plant Name:
Source: Date:
Fidlar Compressor Station Superior 12G-825 (FS02) 06/30/11
Technicians: WM&JC
Engine Speed (rpm) Timing ( 0 BTDC)
Manifold Temperature (°F, L/R) Manifold Pressure (psi, L/R) Catalyst pressure differential (psi) Catalyst inlet temp (°F) Catalyst outlet temp (°F) Measured BSFC (Btu/hp-hr) Horse ower h
NOx (ppmv) 02(%) CO2(%) Fo Factor
NOx (lbs/hr) {Limit= 4.68}
NOx (g/hp-hr) {Limit= 2.0}
NOx (tons/yr)
902 35
72/71 298 / 293
0.4 1191 1237 8416
1.80
0.81
7.88
905 35
61 / 59 305 I 300
0.5 1198 1236 8353
2.59
1.17
11.34
Testing by TRC, Albuquerque, New Mexico
901 35
64/ 63 304 I 301
0.5 1198 1248 8511
2.32
1.05
10.17
2.24
1.01
9.80
Questar Pipeline Fidlar CS
Test Date: 06/30/11 Project No. 185632
Page 12 of 51
Mr. Scott Bassett Questar Corporation PO Box45360 Salt Lake City, UT 84145
Dear Mr. Bassett:
July 3, 2012
Re: Engine Emission Testing For OPL, Fidlar 2 Facility, Permit V-OU-0002-05.01.
Oasis Emission Consultants, Inc. was requested to perform an engine emission test on a Superior 120-825 rich bum engine (Permit V-OU-0002-05.01) located in Utah.
Emission Levels
The average recorded levels were found to comply with emission levels stipulated in the permit, as shown in the attached report, and summarized below.
Emission Unit
/BHP-hr lbs/hr
Avg NOx 1.00 2.34
Catalyst Parameters (Averaged Over 3 Test Runs)
DP inH20 0.5"
Testing Protocol
The attached report was generated using standard CEMS equipment and methodologies as required by EPA 40 CFR 60(A) Methods 1-4 & 7E.
Mr. Scott Bassett Questar Corporation PO Box45360 Salt Lake City, UT 84145
Dear Mr. Bassett:
July 10, 2013
Re: Engine Emission Testing For OPL, Fidlar 2 Facility, Permit V-OU-0002-05.01.
Oasis Emission Consultants, Inc. was requested to perform an engine emission test on a White Superior 12G-825 rich burn engine (Permit V-OU-0002-05.01) located in Utah.
Emission Levels
The average recorded levels were found to comply with emission levels stipulated in the permit, as shown in the attached report, and summarized below.
Emission Unit
/BHP-hr lbs/hr
Avg NOx 1.02 2.03
Catalyst Parameters (Averaged Over 3 Test Runs)
DP inH20 0.4"
Testing Protocol
The attached report was generated using standard CEMS equipment and methodologies as required by EPA 40 CFR 60(A) Methods 1-4 & 7E.
ITEM 4 ATTACHMENT
UNIT FS02 EMISSION CALCULATIONS
Fidlar Compressor Station Potential Emissions for Reciprocating Engines
- ---- ',- --- ---- -----
Maximum Annual Equivalent
Engine Operating Load Hourly Heat Emission Rating Hours Factor Input
Unit ID Source Description (hp) (hr/yr) (%) (MMBtulhr) EHP 1 AOP 1 LF' HHJ''
FS02 White Superior. 12G-825, Reciprocating Gas Engine 1,061 8,760 100 10.79 FS07 Cummins GTA28CC Stand-By Ensiine 643 500 100 6.54
1 Engine rlh'lg btidd on eq~ment design Cummins GT A28CC deratcd 7.2% for~ based on manufacturer's \llerature 2 Annual operati'l8 hours assumed tobe 8,760 hours per year excepl for stand-by WI.its, which are assumed to operate no more than 500 hours per year 3 Load factor based on operator estimate
~ Equivalent hourly heat mpUl calculated bucd on lhe engine rating in hp, AP-42 hpto Btw'hr conYCl'Sion factor, and assumed fuel efficiencyof2S'Y,
PM11 so, NOx co voe (lb/MMBtu) (lb/MMBtu) (glhp-hr) (glhp-br) (g/hp-hr)I (lblMMBtu)
EF' EF' EF' EF' EF 7 EF'
2.06E-02 1.45E-03 2.0 2.0 1.0 I --2.06E-02 1.45E-03 2.0 4.0 LO -
1 PM 1a and voe (for FS07 only) enusslOl'I factors are taken from AP-42, Tabk 3.2-3 (July 2000) PM 10 emission factor is• sum of the filterable and condensable portl()flS. Emission factors adJustcd for narural gas heat content of l,080btu/scf
' sol em1ssl0fl factor 1s determmcd based on maximum sulfur m fuel (FERC Tariff), assuming all sulfur 1s converted to sol. 1 NOx, CO, and voe emission factors to be used for enforceable perrrut limits for FS02 requested by Questar in 2010 modification NC))!;, CO, and voe enuss100 facton for wut FS07 from 40 CFll 60, subpart JJJJ, Table 4
'HAP emission fadors are taken from AP-42 Table 3.2-3 (July2000) Emission factors adjusted for natural gas heat content of 1,080 btu'scf.
lable A-.t(b). Potential (:riterla l"ollutant t.;missions from Reciorocatin2 t.;n2 ines
Maximum Annual
Engine Operatin& Load Emission Rating Hours Factor
Unit ID Source Description (hp) (hr/yr) (%) EHP ADP LF
FS02 White Superior, 12G-825, Reciprocating Gas Engine 1,061 8,760 100 FS07 Cummins GT A28CC Stand-Bv En2inc 643 500 100
Table A-3(c). Potential Hazardous Air Pollutant (HAP) t.;missions from Keci1 rocating Engines
Emission Unit ID Source D~cription
FS02 White Superior, 12G-825, Reciprocating Gas Engine FS07 Cummins GTA28CC Stand-Bv Enlrine
Example C4lC11letio111 for Vnh JD FS01 Hourly Heat Input (HHI):
I. HHI •(EHPXC.F.Xl/fuel efl)(I MMBtu/10"6 Btu)•
S02 Emission Factor:
Maximum Annual
Engine Operating Load Rating Hours Factor
(hp) (hr/yr) ('/,) EHP ADP LF
1,061 8,760 100 643 500 100
EHP = Engine Rating C.F. = Conversion Factor, HP to Btu/hr fuel eff = Fuel Efficiency
2. EF • (S)(MW)(lb mol/385.1 sci)(! scf/1000 BtuXI0"6 Btu/MMBtu) •
PM10 Hourly Emission Rates (HER): 3. HER,...,,,- (EF)(HHIXLF/100) ~
NOx Hourly Emission Rates (HER): 4. HER,...,.~ (EFXTHPXI lb/453.5924 gXLF/100) •
PM11 Annual Emission Rates (AER): 5. AER,,, • (HERXAOP)(I ton/2000 lbs) -
Questar Pipeline Company Fidlar Compressor Station
S = Sulfur in Fuel MW= Molecular Weight of S02
EF = Emission Factor HHl = Hourly Heat Input LF = Load Factor
EF"" Emission Factor THP = Turbine Rating LF = Load Factor
HER = Hourly Emission Rate AOP "" Annual Operating Hours
Equivalent Hourly Heat
Input
(MMBtu/hr) HHI
10.79 6.54
Equivalent Hourly Heat
Input (MMBtu/hr)
HHI
10 79 6.54
Hourly Emission Rates
PM11, so, (lb/hr) (lb/hr) HER HER
0.22 0.02 0.13 9.46E-03
Formaldehyde Acetaldehyde (lb/hr) HER
2.34E-Ol l.42E-OI
10.79 MMBtu/hr
1,061 HP 2,543 Btu/hr 0.25
I .45E-03 lb!MMBIU
8.7 ppmv 64 lbnb-mol
0.22 lbslhr
2.06E-02 lbiMMBtu 10.79 MMBtu/hr 100%
4.68 lbslhr
2.0 s/hp-h, 1,061 HP 100%
0.97 tpy
0.22 lbslh, 8,760 (he/yr)
(lb/hr) HER
l.19E-02 l.93E-02
NOx co voe PM11 (lb/hr) (lb/hr) (lb/hr) (tpy) HER HER HER AER
4.68 4.68 2.34 0.97 2.84 5.67 1.42 0.03
Hourlv Emission Rates
Acrolein Benzene Toluene Ethyl Benzene (lb/hr) (lb/hr) (lb/hr) (lb/hr) IJER HER HER HER
3.0IE-02 LSIE-02 6.J8E-03 2.83E-04 1.82E-02 1.09E-02 3.86E-03 1.72E-04
Sourtt of Data: Calculated
Equipment Design AP-42, Appendix A, Conversion Factors (9/85) Engineering Estimate
Source of Data: Calculated
Based on max Sulfur from FERC tariff Periodic Table
Source of Data: Calculated, PM 10 line item
AP-42, Fifth Edition, Table 3.2-3, (7/00) Equipment Design Operator Estimate
Source of Data: Calculated, NOx line item
Vendor Data Equipment Design Operator Estimate
Source ofD1ta: Calculated, PMio line item
Calculated, see example calc 3 Continuous Operation
Emission Factors
Formaldehyde Acetaldehyde Acrolein (lb/MM Btu) (lb/MMBtu) (lb/MMBtu)
EF' EF' EF'
2.l 7E-02 2.95E-OJ 2.78E-OJ 2.17E-02 2 95E-03 2.78E-03
Annual Potential Emissions
so, NOx co (tpy) (tpy) (tpy) AER AER AER
om 20.49 20.49 2.36E-03 0.71 1.42
Xylene Naphthalene Formaldehyde (lb/hr) (lb/hr) (tpy) HER HER AER
2.ZJE-03 1.1 IE-03 I.OJE+OO l.35E-03 6.72E-04 3.55E-02
Benzene Toluene Ethyl Benzene Xylene Naphthalene (lb/MMBtu) (lblMMBtu) (lblMMBtu) (lb/MM Btu) (lb/MMBtu)
EF' EF' EF' EF' EF'
l .67E-OJ 5.91E-04 2.6JE-05 2.06E-04 103E-04 1.67E-03 5.91E-04 2.63E-05 2.06E-04 L03E-04
voe (tpy) AER
10.25 0.36
Annual Potential Emissions
Ace ta ldehyde Acrolein Benzene Toluene Ethyl Benzene Xylrne Naphthalene (tpy) (tpy) (tpy) (tpy) (tpy) (tpy) (tpy) AER AER AER AER AER AER AER
l.40E-01 l.32E-OI 7.91E-02 2.79E-02 1.24E-03 9.76E-03 4.86E-03 4.83E-03 4.55E-OJ 2.74E-OJ 9.66E-04 4.29E-05 3.38E-04 L68E-04
June 2013
ITEM 5 ATTACHMENT
GREENHOUSE GAS CALCULATIONS
Questar Pipeline Company
Facility Name: Fidlar Comgressor Station State: Utah (Uintah & Ouray)
PTE Combustion Sources:
Fidlar Compressor Station
C02E Emissions Estimate
97761.60 94520.40 97761.60
324558.00 3270.00
0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00
1 Refer to Subpart C 98.30(a) for sources included in source category; per 98.30(b), this source category does not include: (1) Portable equipment, as defined in §98.6. (2) Emergency generators and emergency equipment, as defined in §98.6. (3) Irrigation pumps at agricultural operations.
5183.32 5011.47 5183.32 17208.07
173.38 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00
(4) Flares, unless otherwise required by provisions of another subpart of 40 CFR part 98 to use methodologies in this subpart.
0.10 0.01 5 188 0.09 0.01 5 016 0.10 0.01 5188 0.32 0.03 17 225 0.00 0.00 174 0.00 0.00 0 0.00 0.00 0 0.00 0.00 0 0.00 0.00 0 0.00 0.00 0 0.00 0.00 0 0.00 0.00 0 0.00 0.00 0 0.00 0.00 0
Total 32,792
Questar Pipeline Company Fidlar Compressor Station
2 Calculating source specific heat input (mmBtu) Engine/Turbines
Heater/Boilers
hp = average operating horsepower or maximum rated Btu/hp-hr= BSFC, manufacturer specified or assumed conservative estimate
hrs = operating hours per year; actual or max 8760
mmBtu = hp I Btu I hrs hp-hr
mmBtu/hr = rated capacity of equipment hrs = operating hours per year; actual or max 8760
mmBtu = mmBtu I hrs hr
3 Calculating mass emissions (metric tons) of GHGs using source specific heat input (mmBtu) Tier 1 Methodology
tonne GHG = 1 x 10-3 x EF GHG x mm Btu
0.001 tonne/kg Conversion factor from kilograms to metric tons. 53.02 kg CO2/ mmBtu Default CO2 emission factor (EF); [Table C-1] - fuel type: natural gas
1.00E-03 kg CH4 / mmBtu Default CH4 emission factor (EF); [Table C-2] - fuel type: natural gas 1.00E-04 kg N20 / mmBtu Default N20 emission factor (EF); [Table C-2] - fuel type: natural gas
110 CO2 lb/mmbtu AP-42 Table 3.1-2a - turbines 0.003 N20 lb/mmbtu AP-42 Table 3.1-2a - turbines
4 Calculating Carbon Dioxide Equivalent for each GHG tonne C02e GHG = tonne GHG x GWPGHG
From Table A-1 of Subpart A- Global Warming Potential (100 year time Horizon) 1 GWPc02
21 GWPcH4
310 GWPN20
ft EPAUnited States ,PJ. Environmental Protectiori .... Agency 0MB No. 2060-0336, Aooroval Expires 06/30/2015
Federal Operating Permit Program (40 CFR Part 71)
CERTIFICATION OF TRUTH, ACCURACY, AND COMPLETENESS (CTAC)
This form must be completed, signed by the "Responsible Official" designated for the facility or emission unit, and sent with each submission of documents (i.e., application forms, updates to applications, reports, or any information required by a part 71 permit).
A. Responsible Official
Name: (Last) Heimsath (First) Kim (Ml)_
Title Vice President, Environment, Health, and Safety
Street or P.O. Box P.O. Box 45360
City ____ S"""a=lt~L=a=k~e~C~it..._y _______ State UT ZIP 84145 - 0360
Telephone ~) 324 - 3412 Ext. __ _ Facsimile ~) 324 - 3883
8. Certification of Truth, Accuracy and Completeness (to be signed by the responsible official)
I certify under penalty of law, based on information and belief formed after reasonable inquiry, the statements and information contained in these documents are true, accurate and comple1¥ ~~
Name (signed) f!t, H -J-k,r (}7 Jcvl-
Name (typed) ___ M ...... s=·~K~im~H~e~im~sa"'"t""""h ______ _ Date: /O / ~ / Zc.,,r 3
EPA Form 5900-02